Consolidated Groups

If companies are consolidated for tax purposes, then there is only one tax return for the consolidated group. That means one R&DTI claim (one Application and one R&D schedule) in which all R&D activities and expenditures across the consolidated group are included.

In general W&A will treat each member of the group as a separate entity, and assess the activities and calculate the expenditures independently, which means a service agreement for each entity. The exception is if the subsidiary exists for accounting reasons (such as paying staff salaries) and there is only one entity undertaking actual activities for R&DTI purposes, in which case only one service agreement is required.