CTA09/Ss 1045 – 1048

Normally pre-trading expenditure is treated by CTA09/S61 as incurred on the day that trading begins and so there is no relief for it until trading starts.

If an SME company incurs qualifying R&D expenditure (CIRD81300) in a pre-trading accounting period then the company may make an election to deem 230% of that qualifying expenditure as a trading loss for that accounting period. If an election is made then CTA09/S61 does not apply to the qualifying R&D expenditure.

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