CFM95820 - Interest restriction: tax-EBITDA: R&D Expenditure Credits
TIOPA10/S407(3)(a)
R&D expenditure credits (“RDEC”) provided by CTA09/S104A are excluded from the calculation of adjusted corporation tax earnings when determining a company’s tax-EBITDA.
The RDEC scheme provides a credit of 11% on qualifying expenditure incurred on research and development.
Further guidance on the RDEC scheme can be found at CIRD89700.
Effect for tax-EBITDA purposes
The RDEC scheme is one of the qualifying tax reliefs specified as an excluded amount in TIOPA10/S407(3).
The receipt of an RDEC would have the effect of increasing a group’s interest allowance if included as an income item for tax-EBITDA purposes. This would serve to increase the benefit received for companies claiming the RDEC beyond the intention of the original relief.
Consequently, any R&D expenditure credits received under CTA09/S104A should not be brought into account when calculating taxable total profits of the period to determine a company’s tax-EBITDA.