Expenditure was not ‘subsidised expenditure’ for research and development relief purposes, and the expenditure was not incurred by the company in carrying on activities which were contracted out to it by any person. 

Summary 

Expenditure was not ‘subsidised expenditure’ for research and development (R&D) relief purposes, and the expenditure was not incurred by the company in carrying on activities which were contracted out to it by any person. 

Background 

The appellant company (C), a specialist refurbishment and fit-out contractor, provided specified works to clients for an agreed price. The terms and conditions between C and the clients were set out in construction contracts. Many projects involved taking concept designs through to construction. C agreed to undertake the financial and development risk in delivering the project. Sometimes during the