(a) A credit under this subchapter for qualified research expenses incurred by a member of a combined group must be claimed on the combined report required by § 171.1014 for the group, and the combined group is the taxable entity for purposes of this subchapter.
(b) An upper tier entity that includes the total revenue of a lower tier entity for purposes of computing its taxable margin as authorized by § 171.1015 may claim the credit under this subchapter for qualified research expenses incurred by the lower tier entity to the extent of the upper tier entity’s ownership interest in the lower tier entity.