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A company inquired whether it could apply the Corporate Tax R&D+i deduction to costs for projects outsourced to a group company whose staff already receive Social Security relief for those same researchers. The Directorate General for Tax (DGT) ruled that it is not possible to claim both incentives for the same researchers, unless the company qualifies as an innovative SME.
Companies must carefully manage the overlap between Social Security relief and R&D tax credits to avoid double-dipping, unless they meet the specific criteria for intensive R&D SMEs.
The tax team reviews your specific situation.
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