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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 / D1.412 Clinical trial subjects and contributions to independent R&D
Commentary

D1.412 Clinical trial subjects and contributions to independent R&D

Corporate tax

Payments to the subjects of clinical trials is qualifying R&D expenditure for each of the R&D tax reliefs under both the pre- and post-April 2024 schemes (see D1.401)1.

Contributions to independent research are only qualifying expenditure for large companies and only for accounting periods beginning before 1 April 20242.

Clinical trials subjects

Claims for R&D relief may be made for relevant payments to the subjects of a clinical trial. Clinical trial means an investigation in human subjects undertaken in connection with the development of a health care treatment or procedure. A relevant payment in relation to the subject of a clinical trial is a payment to him for participating in the trial3.

This legislation was enacted because, by virtue of being volunteers, payments to clinical trial subjects were not allowable as staff costs.

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Web page updated on 17 Mar 2025 14:32