Some initial views on the R&D claim Additional information form.

The additional information form (AIF) has become mandatory for all R&D claims filed from the 8th August 2023. The details can be found here. The form must be filed before a tax return containing R&D numbers is made. The CT600 must check box 657 to indicate the form has been filed. But a software glitch does exist around this, so see the advice here if you run into a problem.

The process for filing an R&D claim from now is two step, and the steps must be completed in order.

1. File the additional information form (AIF). You should save it after submission for your records, and it has a submission receipt at the end of the PDF you save. You will also get a confirmation email after submission.
2. File the company tax return including the relevant R&D entries. Box 657 is new and relates to the AIF. The return is how you claim the financial benefit from the R&D claim but that benefit cannot be claimed without step 1 the AIF.

My initial views are that this form is a positive. Implementation has gone relatively well. It has not been disruptive for our company. We have always focused on best practise and trying to provide HMRC what they want to justify a claim in terms of the detail. The form requirements were not much different than the information we have been supplying to HMRC for over a decade. Nothing about it was disruptive.

I could see it being disruptive for claimants who do not have a good process or a good understanding of the R&D claim requirements. But to be honest it can only be viewed as careless to put in claims without the supporting information that shows that the Guidelines have been carefully considered. This is the point of the new requirement, to force claimants to consider the Guidelines and provide evidence supporting the claim.

I have seen some misinformation and some poor behaviour around the change.

1. An accountancy firm, an auditor, looking to charge £975 plus VAT, for completing the additional information. This was just for filing out the form, not advising and helping to document the information that goes on the form, which is the more technical and time consuming part. I have completed a large number of AIF forms, it is just data entry/copy and paste once you have collected and checked the information required, it has never taken more than a hour. It is a bit predatory to seek to charge so much for such a mundane task just because something is new. Our fees were not increased due to this form. We complete it for clients at no extra charge.
2. I have also seen a lot of marketing around software to fill out the AIF form, as filing it out is claimed to be arduous. My personal view is that it is not arduous. It is not necessary to buy software. That appears to be an attempt to create a market as a result of a change that does not really exist. The hard bit is understanding the Guidelines and collecting the information not putting it in the form.
3. I have also seen R&D consultancies fear marketing around the form. Stating it takes anything from 8-30 hours to file it. I have to be careful here because a distinction exists between the work to establish if a claim is valid, and collecting that evidence, and actually filing the form. The first part should have always been part of an R&D claim process that takes due care and does take time. But as already stated the second part takes less than a hour.

If you have been filing R&D claims without knowledge of the relevant “rules” then that is careless behaviour. That should not happen with numbers relating to a company tax return. The new form, correctly considered, makes it impossible to do that. Which is why it is a good form and a good move. It should not be feared by those behaving correctly. If you do need help preparing a claim, this what we do and all we do, so please get in touch.

Christopher Toms MA MAAT – Compliance Director RandDTax.