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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.4 Research and development tax reliefs /Eligible expenditure for R&D tax relief / D1.409A Externally provided workers
Commentary

D1.409A Externally provided workers

Corporate tax

Expenditure on externally provided workers may qualify for each of the R&D tax reliefs under both the pre- and post-April 2024 schemes (see D1.401)1. Externally provided workers are generally workers who are not employees of the company carrying on the R&D, but are instead paid through some intermediary, such as an agency.

Definition of externally provided workers

A person is an externally provided worker in relation to a company if each of the following conditions are satisfied2:

  1. Ìý

    (a)ÌýÌýÌýÌý the worker is an individual

  2. Ìý

    (b)ÌýÌýÌýÌý the worker is not a director or employee of the company

  3. Ìý

    (c)ÌýÌýÌýÌý the worker personally provides, or is under an obligation personally to provide, services to the company

  4. Ìý

    (d)ÌýÌýÌýÌý the worker is subject to (or to the right of) supervision, direction or control by the company as to the manner in which those services are provided

  5. Ìý

    (e)ÌýÌýÌýÌý the worker's services are supplied to the company by or through the staff provider (whether or not the worker is a director or employee

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