Chapter ERSM100400

Published date18 May 2016
Record NumberERSM100400
CourtHM Revenue & Customs
IssuerHM Revenue & Customs
Definitions: ‘Research institution’

Under ITEPA03/S457 this can be:

  1. any publicly funded university or other institution as defined in section 41(2) of the Higher Education Act 2004 or
  2. any institution that carries out research activities otherwise than for profit and that is neither controlled nor wholly or mainly funded by a person who carries on activities for profit.

There is provision for this definition to be amended if a RI comes to light that is not covered by the legislation.

Examples 13

The following examples illustrate the operation of these rules:

  • A medical charity sets up a subsidiary for research. This will be a RI within s457(1)(b);
  • A multinational pharmaceuticals group has several research subsidiaries. They often work in conjunction with university research departments. None of the subsidiaries will qualify as a RI...

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