Companies that incur research expenses can, in principle, benefit from a tax credit (CIR(1)).

In this respect, the tax authorities have just indicated that recruitment aid (work-study program, jobseeker, disabled worker, etc.) that is not conditional on the recruitment of the person recruited to research does not have to be deducted from the basis for calculating the CIR, even if this person is required, in practice, to participate in these operations.

In addition, it specified that personnel expenses incurred in the context of an umbrella company may also be considered in the calculation base of the CIR (and the innovation tax credit), provided that:

• the umbrella company complies with the conditions set out in the Labor Code,
• the ported employees conduct R&D operations on the premises and with the resources of the client company of the umbrella company,
• and only the remuneration and social security contributions of researchers and technicians directly and exclusively assigned to research are considered, in proportion to the time spent on these operations, and therefore excluding other costs included in the price of the service (e.g., personnel management costs).

Reminder: Wage portage allows companies to call on external human resources, for a fixed period, to conduct an occasional task that is not part of their normal and permanent activity or to conduct a one-off service requiring expertise that they do not have internally. This loan of labor isn’t free of charge and requires the conclusion of a commercial contract for the provision of wage portage between the umbrella company and the client company and an employment contract between the ported employee and the umbrella company that pays him.

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