BOFiP clarifies the definition of ORDC for the Collaborative Tax Credit (CICo)

10 April 2025

Following the public consultation opened by the tax authorities on April 13, 2023, a updated comments on the Collaborative Research Tax Credit (CICo) was published in the BOFiP database on March 26, 2025. (BOI-BIC-RICI-10-15-10).

This new version makes a few minor adjustments, in particular to the definition of Research and Knowledge Dissemination Organizations (ORDC) and their ability to carry out economic activities, while incorporating the latest European regulatory developments.

Here are the main changes:

1 Definition of eligible ORDCs

Before (April 13, 2023) ORDCs had to carry out predominantly non-economic activities to be eligible.
Now (March 26, 2025) ORDCs can now carry out economic activities, provided that these are kept separate from non-economic activities (research, teaching, dissemination of knowledge).

2 ORDC's main objective

Before No explicit details on the main objective of ORDCs.
Now The ORDC's primary objective must be to carry out research activities, or to disseminate the results of these activities widely through teaching, publications or knowledge transfer. These activities are considered non-economic under European law.

3 Cumulative conditions for ORDCs

The three cumulative conditions are now required for an ORDC to be eligible:

R&D activities.
Carry out these activities independently.
Separate accounting for financing, costs and revenues related to economic activities. The previous condition requiring ORDCs to engage "predominantly" in non-economic activities has been removed.

4. alignment with European regulations

The BOFiP explicitly incorporates the definition set out in European Commission communication no. 2022/C 414/01, specifying the criteria for state aid for R&D. These adjustments strengthen compliance with European standards.