The key things you need to know about the new claim notification form for R&D Tax claims.
If your company has never claimed R&D Tax Relief before or has not claimed in the last three years, you may need to submit a claim notification form before you file.
This requirement applies to accounting periods starting on or after 1 April 2023. It is one of a series of changes the government introduced to protect the R&D Tax Relief scheme from abuse.
The form is separate from the overall deadline for submitting an R&D Tax claim, which is two years after the end of the accounting period in which the R&D took place.
This blog explains the key things you need to know about the claim notification form, including when you need to submit it by, what information you need to provide, and what happens if you miss the deadline.
If you have any questions about the form or would like support on your upcoming R&D Tax claim from a trusted provider, please get in touch. Our R&D Tax experts would be happy to help.
Do I have to submit a claim notification form?
You can work out whether you need to submit a claim notification by answering six questions.
Question 1: When did your accounting period start?
As I mentioned in the introduction, this requirement only applies to accounting periods beginning on or after 1 April 2023.
If the development work you’re looking to claim for took place in an accounting period starting on or after 1 April 2023, go to question 2.
If not, you don’t need to submit a claim notification form.
Question 2: Are you filing your R&D Tax Relief claim within 6 months of the end of the accounting period in which the R&D took place?
If yes, you don’t need to file a claim notification form.
The claim notification requirement only applies to companies filing for R&D Tax Relief more than 6 months after the end of the accounting period in which the relevant R&D took place.
So, for example, if the R&D occurred in an accounting period ending 31 December 2024, you don’t need to file a claim notification form if you file for R&D Tax Relief before 30 June 2025.
If you are filing for R&D Tax Relief more than 6 months after the end of the relevant accounting period, move to question 3.
Question 3: Have you claimed R&D Tax Relief before?
If you have not claimed R&D Tax Relief before, and you are planning to file for R&D Tax Relief more than 6 months after the end of the relevant accounting period, you will need to file a claim notification form.
If you have claimed before, move on to question 4.
Question 4: Did you file within the last three years?
When was the last time you filed for R&D Tax Relief?
If it was more than 3 years before the claim notification form deadline, which is 6 months after the end of the accounting period you’re claiming for, you will need to file a claim notification form.
To clarify: the 3-year window we’re talking about ends 6 months after the end of the accounting period in which the R&D in your claim took place.
For example, if your accounting period ended on 31 December 2024, the period would end on 30 June 2025 and start on 30 June 2022.
If you last filed for R&D Tax Relief during this 3-year window, move on to question 5.
Question 5: Did you file by amending your company tax return?
This next question relates to how you filed for R&D Tax Relief.
This matters because, for the purposes of the claim notification form, filings made with a company tax return are treated differently from claims made by amending a company tax return that has already been filed.
If you filed for R&D Tax Relief when you submitted your company tax return, and it was during the 3-year period described in question 4, you don’t need to file a claim notification form.
This is true even if you are filing for R&D Tax Relief more than six months after the end of the accounting period that contains the R&D you’re claiming for.
However, if you only ever filed for R&D Tax Relief by amending your company tax return once it has been submitted, the question becomes, ‘When did you file the amended return?’
Question 6: When did you file the amended return?
If you claimed by amending your return after 1 April 2023, then, for the purposes of the claim notification form, it does not count as you having filed for R&D Tax Relief. As a result, you will need to submit a claim notification form, bearing in mind the information in questions 1-5.
However, if you amended your return before 1 April 2023, and within the 3-year window described in question 4, then it will qualify as a filed claim, and you won’t need to submit a claim notification form.
What is the deadline for the claim notification form?
The deadline for submitting the claim notification form is six months after the end of the accounting period you’re claiming for.
So, if you were claiming for work conducted in an accounting period ending 31 December 2024, you would have until 30 June 2025 to file the form.
You then have up to two years to file your claim.
If you are claiming for two accounting periods, the deadline is six months after the end of the second accounting period the claim applies to.
While you can submit the claim notification form as soon as your accounting period starts, that’s not necessarily a good idea.
The form asks you for a high-level summary of your R&D activities. Unless you have a good idea about what R&D you’re going to conduct, it’s best to wait until later in your accounting period or until after your accounting period has finished to file your claim notification form.
What happens if I miss the deadline?
If you miss the claim notification form deadline, you most likely won’t be able to claim R&D Tax Relief for that accounting period.
HMRC deals with late claims in accordance with Statement of Practice 5 (2001).
The Statement says, “the time limits allowed for making claims[…]should generally be adequate, and the Commissioners for HMRC will not make routine use of their powers to accept claims made outside these limits.”
In other words, HMRC is unlikely to accept your form if you submit it after the deadline.
HMRC can make an exception if you submitted the form late for reasons beyond your company’s control. For example, the person responsible for the form was ill.
However, as exceptions are made on a case-by-case basis, it’s prudent to assume HMRC will reject your form, and you won’t be able to make a claim.
What information do I need to submit in the claim notification form?
You will need to submit the following information on the claim notification form:
- Your company’s Unique Taxpayer Reference (UTR)
- The name of the main internal R&D contact that’s responsible for your R&D claim
- The contact details of any agent involved in your R&D Tax claim, such as an R&D Tax Relief consultant
- The start and end date of the accounting period you’re claiming for
- A high-level summary of your planned activities
You don’t need to include evidence to prove these activities met the definition of qualifying R&D on your form. However, you will need to fill in the additional information form (AIF) when you submit your claim.
Who can submit the claim notification form?
The following people can submit a claim notification form on behalf of your company:
- A representative of that company
- An agent acting on the company’s behalf
Get help from our R&D Tax Relief experts
Looking for help preparing and submitting the claim notification form? Or wondering what to do if you’ve missed the submission deadline?
GrantTree’s R&D Tax Relief experts are here to help. With more than 14 years of experience filing compliant claims and over £400 million secured for our clients, our team are perfectly placed to help you navigate this important scheme.
Just get in touch, and one of our team will be right with you.
