Corporation Tax Act 2009 section 926

Contributions to expenditure

Section 926 restricts the amount of expenditure a company can claim for patent-related tax relief where that expenditure has been funded or reimbursed by a public body or another person.

  • Expenditure claimed under sections 910, 913 and 924 is disallowed to the extent it has been met, directly or indirectly, by a public body or by someone other than the company itself
  • A "public body" is defined broadly to include the Crown, any government, local authority or other public authority, whether in the United Kingdom or elsewhere
  • The restriction does not apply to incidental expenses incurred by a seller of patent rights, because the relevant charge already operates on the net proceeds of the sale
  • An exception to the general rule exists where the contribution is not made by a public body and is not eligible for tax relief in the hands of the contributor (as set out in section 927)

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