A:

The Simple answer is ‘No’. This is because they go in as subcontracts and there are no overheads on subcontracts.

The Commission official answer is:

“…The 20% flat rate for indirect costs (whether the contractor is in FCF or AC) is to be applied to direct additional (for AC) or direct costs (for FCF) MINUS the costs of subcontracts. Therefore any audit certificates that are subcontracted would not be eligible for the 20%...”