Pharmaceuticals/ subcontracting
10/11/1995
Query
Does the subcontracting out of the granulation process, disqualify a process from manufacturing relief?. The remaining process involves the sampling, testing and mixing of specified quantities of ingredients to produce a homogeneous mixture. The mixture is a new product distinguisable from the individual ingredients. (Contrast with the mixing of fruit where the character of the individual ingredients remain).
Decision
Allowed. The remaining activities constitute manufacture in their own right.
Corporation Tax
Section 443, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:6492/95