R&D tax relief claim notification requirement
Overview
For accounting periods beginning on or after 1 April 2023, if you are planning to make an R&D claim you must submit a claim notification form if:
- you are claiming for the first time
- your last claim was made more than 3 years before the last date of the ‘claim notification period’ – there are some notable exceptions to this mentioned below which are critical to understand
R&D claims submitted without a claim notification form, if required, will not be valid. Fairly straightforward, right? Wrong.
What is the claim notification period?
You must submit your claim notification within the ‘claim notification period’ – this depends on the ‘period of account’ (the time covered by your financial statements, which could be longer than 12 months) and the ‘accounting period’ that falls within your period of account (the time covered by your corporation tax return, which cannot be longer than 12 months).
The claim notification period starts on the first day of the ‘period of account’ and ends 6 months after the end of the ‘period of account. If your ‘period of account’ is 12 months or less, your ‘accounting period’ will usually cover the same time as your ‘period of account’. If the ‘period of account’ is longer than 12 months it will include 2 or more ‘accounting periods’ and in this case the claim notification period is the same for all accounting periods within the ‘period of account’. If you are claiming for a ‘period of account’ that is more than 12 months, you only need to submit the claim notification form for one of the accounting periods.
There are some good worked examples of the ‘claim notification period’ on the gov.uk pages at the link below.
Are there any pitfalls?
Care must be taken to fully understand whether notification is required in the case where you have a history of submitting R&D claims and think you are therefore exempt from the requirement to notify. There are some exceptions that you need be aware of.
If you have claimed R&D tax relief within 3 years of the last date of the relevant claim notification period you will still have to submit a claim notification form if:
- HMRC rejected your R&D tax relief claim for an earlier period by removing it from your tax return
- you claimed R&D tax relief for an accounting period beginning before 1 April 2023 by amending your tax return and the amendment was received on or after 1 April 2023
In addition, changes to your period of account will change the claim notification period and may invalidate a claim notification form that has already been submitted, meaning that another notification is required. Shortening a period of account will bring forward the end of the claim notification period so you will need to ensure you are able to submit the claim notification within the revised period.
What information is required for the claim notification?
The notification requires the following information:
- the company’s Unique Taxpayer Reference (UTR) — this must match the one shown in your Company Tax Return
- the contact details of the main senior internal R&D contact in the company who is responsible for the R&D tax relief claim, for example a company director
- the contact details of all agents involved in the R&D tax relief claim — including any agent who has given advice, analysed costs, helped prepare technical assessments, given information for or completed the online forms or Company Tax Return
- the accounting period start and end date that you’re claiming the tax relief or expenditure credit for — this must match the one shown in your Company Tax Return (if you change your period of account after submission of the claim notification you will need to submit a new one to cover the revised period of account and such a change could also impact the claim notification window so take care)
- the period of account start and end date
- a summary of the high-level planned activities, for example if you’ve developed software you’ll need to include what it’ll be used for to show that the project meets the standard definition of R&D— you do not need to include evidence on the claim notification form, but you’ll be asked to give additional information when you make your claim
How do I make the claim notification
The online form can be accessed at the link below, keep scrolling until you get to the green ‘Start now’ button towards the end of the page:
