The statute provides that, to be eligible for relief, expenditure within the qualifying categories must have been allowable as a deduction in computing the profit of the trade for which the R&D is relevant.
Pre trading expenditure
Where expenditure is incurred for the purposes of a trade before that trade commences, the expenditure can generally only be allowed as a deduction in computing the profit as if the expenditure had been incurred on the first day of the trade (CTA09/S61). The exception to this is under the SME scheme and is dealt with at CIRD90200. Pre trading expenditure under the large company scheme is dealt with at CIRD88000.
Deductibility in computing profit of expenditure incurred in an accounting period beginning on or after 1 January 2005