Corporation Tax Act 2009 section 1171

Staffing costs attributable to relevant land remediation

Section 1171 sets out how a company determines which of its staffing costs qualify as attributable to relevant land remediation for the purposes of the land remediation tax relief.

  • Only staffing costs for directors or employees directly and actively engaged in land remediation qualify for relief.
  • If a director or employee spends less than 20% of their working time on remediation, none of their staffing costs qualify; if they spend more than 80%, all of their staffing costs qualify.
  • Where time spent on remediation falls between 20% and 80%, only the appropriate proportion of staffing costs is treated as attributable.
  • Staff providing support services such as secretarial or administrative work are not treated as directly and actively engaged in remediation, so their costs do not qualify.

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