HM Revenue & Customs (HMRC) has been notably flexible over the past 18 years in how it has accepted claims for R&D tax credits. This contrasts with the strict rules for the filing of a company’s CT600 tax return. It has been a formal requirement for a while that CT600s must be digitally filed via HMRC’s online portal.
Meanwhile, HMRC has been prepared to accept changes to take account of R&D tax credit claims via letter or email. This more relaxed process is about to end.
R&D Tax Claim Filing Changes from 1 April 2019
From 1 April 2019, your R&D tax claim must be accompanied by a fully completed CT600 tax return. Plus a supporting tax computation and the R&D claim report and calculations. There will be a transitional ‘soft touch’ until 30 June 2019.
Our View on the Proposed Changes
In our view, this change makes complete sense. It helps ensure that the full tax picture is taken into account when you prepare an R&D tax claim. Changes made to the overall tax status (e.g via side-letter or email) could risk overlooking other reliefs or pitfalls. Plus, potentially leave incumbent accountants or advisors in the dark as to what changes have been filed with HMRC…
In a recent call with HMRC, it was suggested that all R&D tax agents will be required to hold formal HMRC agent filing permissions. This change would be a welcome step forward.