As of 8 August 2023, all Research and Development (R&D) Tax Credit claims require the submission of an online Additional Information Form (AIF) providing supplementary project details.
The form must be completed prior to the submission of the company tax return. If the form is not submitted, the R&D claim will not be incorporated into the company tax return (CT600).
The form can be completed by a representative of the company or an agent, but it must include information about the senior internal R&D contact who is responsible for the claim, as well as any agent involved in the claim process.
HM Revenue & Customs (HMRC) has expressed concerns about the behaviour of some agents in relation to R&D.
The requirement for details about the agent and a senior responsible individual is designed to foster transparency in the claim process and ensure that R&D compliance is supervised at a high level within organisations.
The form applies both to ongoing projects and accounting periods that have already concluded.
Companies must capture all necessary information, and they may need to adjust their internal systems to collect this information efficiently.
The form also demands details about qualifying expenditure, encompassing qualifying indirect activities and specifics about the R&D projects undertaken.
Companies with a large number of projects can provide information about a selection of the projects, but this must include at least three projects that account for a minimum of 50 per cent of the qualifying R&D expenditure.
Details must also be provided of advancements in technology, the technological baseline, the technological uncertainties, and the strategies used to overcome them.
There are concerns among some advisers that current reports may not meet the new requirements, particularly if the projects are similar and relate to the same technological uncertainties.
Allocating costs between projects may also pose challenges, potentially leading to increased administrative costs for businesses that comply with the new rules.