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| 1 | --- |
| 2 | name: rd-tax-credits-matrix |
| 3 | description: > |
| 4 | Use this skill whenever a company asks about claiming a research and development tax credit, super-deduction, refundable cash incentive, or grant tied to R&D. Trigger on phrases like "R&D credit", "R&D tax credit", "R&D super-deduction", "RDEC", "merged RDEC", "ERIS", "enhanced R&D intensive support", "SR&ED", "CIR", "Crédit d'Impôt Recherche", "Forschungszulage", "WBSO", "SLIM (Spain)", "credito ricerca", "patent box vs R&D", "R&D in OBBBA", "§174 capitalization", "§41 R&D credit", "JEI / JEU", "China R&D super-deduction", "India R&D §35", "Australia R&DTI", "USDA SBIR", "OECD frascati definition", "qualifying R&D", or any request to compute eligibility, qualifying expenditure, and benefit value of an R&D incentive. Covers 25+ regimes including the post-2024 UK merged RDEC, US §174 capitalisation rules, France CIR, Germany Forschungszulage, Netherlands WBSO and Innovation Box interaction, China 175% super-deduction, India §35, Australia R&DTI, Canada SR&ED. Does NOT cover: patent box (see ip-patent-box-matrix), depreciation of capitalised R&D, grant accounting beyond reference, customs duty on R&D imports. ALWAYS read this skill before assessing R&D credit eligibility or computing a claim. |
| 5 | version: 0.1 |
| 6 | jurisdiction: GLOBAL |
| 7 | tax_year: 2025 |
| 8 | category: cross-border |
| 9 | depends_on: |
| 10 | - cross-border-workflow-base |
| 11 | verified_by: pending |
| 12 | --- |
| 13 | |
| 14 | # R&D Tax Credits / Super-Deductions Matrix v0.1 |
| 15 | |
| 16 | ## What this file is |
| 17 | |
| 18 | **This file is a content skill that loads on top of `cross-border-workflow-base`.** It maps the world's principal R&D tax incentives — credits, super-deductions, refundable cash incentives — as of mid-2025. |
| 19 | |
| 20 | **Tax year coverage.** Current for **fiscal year 2025**, reflecting: |
| 21 | - **UK merged RDEC scheme** (FA 2024) for accounting periods beginning on or after 1 April 2024, replacing the small/mid-size R&D scheme with a single 20% above-the-line credit (~15% post-tax) |
| 22 | - **UK ERIS (Enhanced R&D Intensive Support)** for R&D-intensive loss-making SMEs (40%+ qualifying expenditure ratio) — 86% uplift + 14.5% credit on surrendered loss |
| 23 | - **US §174 R&D capitalisation** still in force per TCJA 2017 amendments (5-year domestic / 15-year foreign amortisation), with continued legislative pressure to restore immediate expensing |
| 24 | - **Germany Forschungszulage** raised to **35%** of eligible costs for SMEs (otherwise 25%) under the Wachstumschancengesetz (March 2024); annual cap of EUR 10 million per claimant |
| 25 | - **France CIR** unchanged at 30% (up to EUR 100m of expenditure; 5% above) |
| 26 | - **Netherlands WBSO** rates and ceilings updated annually |
| 27 | - **OECD BEPS Action 5** Modified Nexus interaction with R&D |
| 28 | - **Pillar Two** — R&D super-deductions can lower ETR below 15% and trigger top-up tax |
| 29 | |
| 30 | **The reviewer is the customer of this output.** R&D claims face significant tax-authority scrutiny. Every output must be reviewed by a credentialed practitioner (typically R&D specialist firms or Big 4 R&D advisory) before any claim is filed. |
| 31 | |
| 32 | --- |
| 33 | |
| 34 | ## Section 1 — Scope statement |
| 35 | |
| 36 | This skill covers: |
| 37 | |
| 38 | - **Qualifying R&D definition** — OECD Frascati Manual and country adaptations |
| 39 | - **Eligibility tests** — taxpayer type, sector, claim history |
| 40 | - **Qualifying expenditure** categories |
| 41 | - **Benefit mechanism** — credit, deduction, refundable cash, super-deduction |
| 42 | - **Filing mechanics and audit risk** |
| 43 | - **Pillar Two interaction** |
| 44 | - **Patent box interaction** (cross-reference) |
| 45 | |
| 46 | This skill does NOT cover: |
| 47 | |
| 48 | - **Patent box / IP regime** computation — see `ip-patent-box-matrix.md` |
| 49 | - **Grant accounting** beyond reference |
| 50 | - **Country-specific R&D wage subsidies** that are not tax credits |
| 51 | - **Depreciation / amortisation** of capitalised R&D assets — see country corporate tax skills |
| 52 | |
| 53 | --- |
| 54 | |
| 55 | ## Section 2 — The Frascati definition of R&D |
| 56 | |
| 57 | **[T1] OECD Frascati Manual (2015 edition):** R&D comprises creative and systematic work undertaken to increase the stock of knowledge, and to devise new applications of available knowledge. Five criteria, ALL of which must be met: |
| 58 | |
| 59 | 1. **Novel** — aimed at new findings |
| 60 | 2. **Creative** — based on original, not obvious, concepts and hypotheses |
| 61 | 3. **Uncertain** — outcome uncertain |
| 62 | 4. **Systematic** — planned and budgeted |
| 63 | 5. **Transferable / reproducible** — leads to results that could be transferred to / reproduced by others |
| 64 | |
| 65 | Three types: |
| 66 | - **Basic research** — experimental or theoretical work without specific application |
| 67 | - **Applied research** — original investigation for specific practical aim |
| 68 | - **Experimental development** — systematic work using existing knowledge to produce new materials, products, processes |
| 69 | |
| 70 | **[T1]** Local regimes adopt Frascati with minor variations. Country-specific exclusions are common (e.g., UK excludes market research; France excludes routine quality control). |
| 71 | |
| 72 | --- |
| 73 | |
| 74 | ## Section 3 — Country regime matrix |
| 75 | |
| 76 | ### 3.1 Europe |
| 77 | |
| 78 | | Country | Mechanism | Headline rate | Notable | |
| 79 | |---|---|---|---| |
| 80 | | **United Kingdom — Merged RDEC** | Above-the-line credit | **20% gross** (≈15% net) | Single scheme from periods beginning 1 Apr 2024. Subcontractor restriction (no overseas R&D from 1 Apr 2024 with limited exceptions). | |
| 81 | | **United Kingdom — ERIS (Enhanced R&D Intensive Support)** | SME loss surrender | **86% uplift + 14.5% credit** | Loss-making SMEs with ≥30% (reduced from 40% by FA(No.2) 2024) qualifying R&D expenditure ratio. | |
| 82 | | **France — CIR** | Refundable credit (4-year carryforward, refund if not used) | **30%** of qualifying expenditure to EUR 100m; **5%** above | Two-fold uplift for young innovative companies; doubling possible for grad-students hired. | |
| 83 | | **France — CII (Crédit d'Impôt Innovation)** | Credit | **30%** of qualifying innovation expenditure to EUR 400k | For SMEs; covers innovation prototyping (not pure R&D). Extended through 2027. | |
| 84 | | **France — JEI / JEU** | Combined tax + social contribution exemption | Up to 100% CIT exemption first year; 50% second year | Young Innovative Enterprises < 8 years old, R&D-intensive. | |
| 85 | | **Germany — Forschungszulage** | Cash subsidy via tax credit | **25%** (large) / **35%** (SMEs since March 2024) | Cap: EUR 10m eligible expenditure per claimant per year (was EUR 4m). Refundable if no tax liability. | |
| 86 | | **Italy — R&D Credit (Credito d'imposta R&S)** | Credit | **10%** basic research; **5%** development; uplift to 15% for South + women + youth | Reduced from prior 12-50% rates. Combined with Italian Patent Box super-deduction. | |
| 87 | | **Spain — R&D Credit (Deducción I+D+i)** | Non-refundable credit + cash conversion option | **25%** (excess over prior 2-year average) + **42%** on the excess; total cap 50% of CIT; cash-out at 80% of credit | Spanish CIT | |
| 88 | | **Netherlands — WBSO** | Payroll tax reduction | **32%** of first EUR 350k of qualifying R&D wages; **16%** above (rates as updated 2025) | Reduces wage tax/social contributions of R&D employees. Stackable with Innovation Box. | |
| 89 | | **Belgium — Partial Withholding Exemption** | Payroll tax exemption | **80%** exemption on R&D wages for qualifying researchers | Stackable with Innovation Income Deduction. | |
| 90 | | **Belgium — R&D Investment Deduction** | Increased depreciation | **15.5%** investment deduction one-shot OR **22.5%** spread | Choice; combined with patent income deduction. | |
| 91 | | **Ireland — R&D Tax Credit** | Refundable credit | **30%** (raised from 25% in FA 2023) | Cash refund possible over 3 years. | |
| 92 | | **Poland — R&D Tax Relief** | Super-deduction | **100% deduction** of qualifying costs; **200%** for wage costs (loss possible) | Combined with IP Box. | |
| 93 | | **Czech Republic — R&D Deduction** | Deduction | **100%** uplift (200% total) of qualifying expenditure | Multi-year carryforward. | |
| 94 | | **Romania — R&D Super-Deduction** | Super-deduction | **50% uplift** (150% deduction) | Plus 16% credit for certain expenses. | |
| 95 | | **Hungary — R&D Super-Deduction** | Super-deduction | **300%** deduction of qualifying expenditure | Limited to entities with own R&D operations. | |
| 96 | | **Slovakia — R&D Super-Deduction** | Super-deduction | **100% uplift** (200% deduction) | Plus 25% increase year-over-year. | |
| 97 | | **Portugal — SIFIDE II** | Credit | **32.5%** basic + uplift to 50% for incremental expenditure | Specific innovation funds. | |
| 98 | | **Norway — SkatteFUNN** | Credit | **19%** SMEs; **19%** large companies | Cap NOK 25m per project. | |
| 99 | | **Sweden — R&D Payroll Relief** | Payroll tax reduction | **20%** of R&D wages, cap SEK 1.5m/month | Plus general tax depreciation for R&D capex. | |
| 100 | | **Denmark — R&D Super-Deduction** | Deduction | **108%** of R&D expenses through 2025 (down from 130%); refundable for loss-makers up to DKK 25m | Negotiated annual extensions. | |
| 101 | | **Finland — R&D Combined Deduction** | Deduction | **150%** general R&D deduction + **50%** R&D wage uplift (combined max 200%) | Plus payroll tax relief | |
| 102 | |
| 103 | ### 3.2 Americas |
| 104 | |
| 105 | | Country | Mechanism | Headline rate | Notable | |
| 106 | |---|---|---|---| |
| 107 | | **United States — §41 R&D Credit (Federal)** | Non-refundable credit | **20%** regular method (over base period); **14%** ASC simplified | Plus 6% payroll tax offset for QSBs. §174 capitalisation 5/15 years amortisation continues in 2025. | |
| 108 | | **United States — State R&D Credits** | Various | 1.5% (NY)-15% (CA additional) | Stackable with federal | |
| 109 | | **Canada — SR&ED** | Refundable / non-refundable credit | **35% refundable** for CCPCs on first CAD 3m; **15% non-refundable** above and for non-CCPCs | Provincial top-ups in ON, QC, BC, MB, NS, SK | |
| 110 | | **Mexico — R&D Tax Credit** | Credit | **30%** of incremental R&D expenditure | Limited budget; advance allocation required | |
| 111 | | **Brazil — Lei do Bem** | Super-deduction + accelerated depreciation | **60-80%** of R&D expenditure deductible (additional to 100% expense); accelerated depreciation of equipment; reduced IPI on imports | Lucro Real taxpayers only | |
| 112 | | **Chile — R&D Credit (Ley 20.241)** | Credit | **35%** of qualifying R&D, refundable | Annual cap UF 15,000 | |
| 113 | | **Argentina** | Credit | Various sector schemes | Subject to currency and macro instability | |
| 114 | | **Colombia** | Deduction + credit | **100%** deduction + **25%** credit on R&D investment | Annual cap | |
| 115 | |
| 116 | ### 3.3 Asia-Pacific |
| 117 | |
| 118 | | Country | Mechanism | Headline rate | Notable | |
| 119 | |---|---|---|---| |
| 120 | | **Australia — R&DTI (R&D Tax Incentive)** | Refundable / non-refundable offset | **48.5%** refundable offset for aggregated turnover < AUD 20m; **38.5%** non-refundable for larger | Loss-making refunds available | |
| 121 | | **Japan — R&D Tax Credit** | Credit | **6-14%** of R&D expenditure (base); plus incremental + open innovation uplifts up to **30%** | SMEs higher base rate; multiple stackable categories | |
| 122 | | **China — R&D Super-Deduction** | Super-deduction | **100%** uplift (200% total deduction) for all industries (extended) | Permanent post-2021 expansion; manufacturing 200% historically maintained | |
| 123 | | **India — §35 Income Tax Act** | Super-deduction | **150%** in-house R&D (DSIR-approved); **100%** outside R&D | Reduced from 200% by Finance Act 2017. Plus weighted deduction for scientific research. | |
| 124 | | **Singapore — R&D Tax Deduction (§14C/§14D ITA)** | Super-deduction | **250%** of qualifying R&D expenditure in Singapore (raised from 150% in Budget 2023) | Cash payout option for SMEs | |
| 125 | | **South Korea — R&D Tax Credit** | Credit | **25-40%** SMEs; **15-40%** large (current vs base year) | Higher rates for "new growth engines" sectors | |
| 126 | | **Taiwan — R&D Investment Tax Credit** | Credit | **15%** of qualifying R&D, capped at 30% of CIT | Modified periodically | |
| 127 | | **Indonesia — R&D Super-Deduction** | Super-deduction | Up to **300%** for specified R&D categories | Pre-approval required | |
| 128 | | **Vietnam** | Deduction | 100% expensable; sector incentives separately | n/a | |
| 129 | | **Thailand — Smart Visa / BOI** | Various | Sector-specific | Combined with BOI incentives | |
| 130 | | **Malaysia — R&D Approved Status** | Deduction | **100%** in-house + special tax allowances | Pre-approval by MIDA | |
| 131 | |
| 132 | ### 3.4 Africa |
| 133 | |
| 134 | | Country | Mechanism | Headline rate | |
| 135 | |---|---|---| |
| 136 | | **South Africa — §11D R&D Deduction** | Super-deduction | **150%** of qualifying R&D expenditure (pre-approval by DST required) | |
| 137 | | **Egypt** | Limited; sector schemes | n/a | |
| 138 | | **Kenya** | Limited; ICT and pharma sector incentives | n/a | |
| 139 | | **Nigeria** | 20% R&D credit (subject to approval) | n/a | |
| 140 | |
| 141 | --- |
| 142 | |
| 143 | ## Section 4 — Computation walk-through (UK merged RDEC example) |
| 144 | |
| 145 | For a UK accounting period beginning on or after 1 April 2024: |
| 146 | |
| 147 | ### Step 1 — Qualifying activity test |
| 148 | |
| 149 | **[T1] BEIS Guidelines on R&D (formerly DSIT Guidelines):** |
| 150 | - Project seeks an advance in science or technology |
| 151 | - Encounters scientific or technological uncertainty that a competent professional could not readily resolve |
| 152 | - The advance must be a genuine advance in the relevant overall field, not just for the company |
| 153 | |
| 154 | ### Step 2 — Qualifying expenditure |
| 155 | |
| 156 | **[T1] Categories (CTA 2009 Part 13):** |
| 157 | - Staff costs (gross salary, employer NICs, pension) |
| 158 | - Externally provided workers (EPWs) — restricted to UK workers post-2024 |
| 159 | - Subcontracted R&D — restricted to UK subcontractors post-2024 (limited overseas exception) |
| 160 | - Consumable items (utilities, materials transformed in R&D) |
| 161 | - Software, data, cloud costs (new from 2023) |
| 162 | - Payments to qualifying bodies (universities, charities, scientific research orgs) |
| 163 | - Externally licensed R&D resources |
| 164 | |
| 165 | Capital expenditure NOT eligible for R&D credit but RDA / R&D Allowances available separately. |
| 166 | |
| 167 | ### Step 3 — Compute the credit |
| 168 | |
| 169 | **[T1] Merged RDEC formula:** |
| 170 | |
| 171 | ``` |
| 172 | Credit = 20% × Qualifying R&D Expenditure |
| 173 | ``` |
| 174 | |
| 175 | Credit is **above-the-line** (treated as taxable income). |
| 176 | |
| 177 | ``` |
| 178 | Net benefit (post-tax) = 20% × QRE × (1 - CT rate) |
| 179 | ≈ 15% for main rate 25% |
| 180 | ``` |
| 181 | |
| 182 | For ERIS (R&D-intensive loss-making SMEs): |
| 183 | |
| 184 | ``` |
| 185 | Uplifted loss = QRE × 186% (the 86% uplift) |
| 186 | Surrendered loss credit = uplifted loss × 14.5% |
| 187 | ≈ 27% net benefit |
| 188 | ``` |
| 189 | |
| 190 | ### Step 4 — Filing |
| 191 | |
| 192 | - Notification of intent to claim required within 6 months of period end if no claim in past 3 years (CT600L) |
| 193 | - Additional Information Form (AIF) required for all claims from 8 August 2023 |
| 194 | - Claim period: 2 years from end of accounting period |
| 195 | - Audit risk: HMRC has expanded R&D enquiry capacity since 2022; expect requests for technical narratives, project documentation, time records |
| 196 | |
| 197 | --- |
| 198 | |
| 199 | ## Section 5 — Computation walk-through (France CIR example) |
| 200 | |
| 201 | ### Step 1 — Qualifying activity (CGI Art. 244 quater B) |
| 202 | |
| 203 | **[T1] OECD Frascati criteria** plus French specifics: |
| 204 | - Basic research, applied research, experimental development |
| 205 | - Includes technological watch (max EUR 60k/yr) and patent expenses (deposit + maintenance + defence) |
| 206 | |
| 207 | ### Step 2 — Qualifying expenditure |
| 208 | |
| 209 | **[T1] Categories:** |
| 210 | - Researcher and technician wages (with 50% uplift for operating costs — "frais de fonctionnement") |
| 211 | - Depreciation of R&D assets |
| 212 | - Subcontracted R&D — to approved bodies only; capped at 2× internal R&D spend OR EUR 12m |
| 213 | - Patent costs |
| 214 | - Standardisation expenses |
| 215 | - Young doctors' wages — doubled for first two years post-graduation |
| 216 | |
| 217 | ### Step 3 — Compute the credit |
| 218 | |
| 219 | ``` |
| 220 | CIR = 30% × QRE up to EUR 100m |
| 221 | + 5% × QRE above EUR 100m |
| 222 | |
| 223 | For overseas territories: 50% on first slice |
| 224 | For young innovative companies: doubled |
| 225 | ``` |
| 226 | |
| 227 | ### Step 4 — Use the credit |
| 228 | |
| 229 | - Offset against CIT due |
| 230 | - Carry forward 3 years |
| 231 | - Refund at end of year 4 if unused |
| 232 | - Immediate refund for SMEs, JEI, young innovative companies, and loss-making companies in conciliation/safeguard |
| 233 | - **Pre-financing schemes** (BPI France) advance the credit |
| 234 | |
| 235 | --- |
| 236 | |
| 237 | ## Section 6 — US §174 capitalisation interaction |
| 238 | |
| 239 | **[T1]** TCJA 2017 amended IRC §174 effective for tax years beginning after 31 December 2021. Key effects: |
| 240 | |
| 241 | - **Domestic R&D expenditure** must be capitalised and amortised over **5 years** (mid-year convention) |
| 242 | - **Foreign R&D expenditure** must be capitalised and amortised over **15 years** |
| 243 | - Affects all R&D expenditure regardless of credit eligibility |
| 244 | - §41 R&D credit base is independent of §174 capitalisation |
| 245 | - **Pending legislation** has not restored immediate expensing as of mid-2025; bipartisan support exists but not enacted |
| 246 | |
| 247 | **[T2]** Cash-flow timing of US R&D expenditure changed materially. R&D-intensive companies face significant Year 1 tax liabilities they did not have pre-TCJA. The §41 credit partially offsets but does not eliminate the cash impact. |
| 248 | |
| 249 | --- |
| 250 | |
| 251 | ## Section 7 — Pillar Two interaction |
| 252 | |
| 253 | **[T1]** Qualified Refundable Tax Credits (QRTCs) — i.e., refundable within 4 years — are treated as **income** in GloBE Income (not as reductions of Covered Taxes). This means refundable credits do not push ETR below 15%. |
| 254 | |
| 255 | Non-refundable / non-qualified credits reduce Adjusted Covered Taxes, lowering ETR. Heavy reliance on R&D super-deductions in low-tax jurisdictions can trigger top-up tax. |
| 256 | |
| 257 | **[T2] By regime:** |
| 258 | - US §41 — non-refundable beyond the QSB payroll offset → reduces Covered Taxes → ETR impact |
| 259 | - UK ERIS — credit refundable in 4 years → treated as income → no ETR push |
| 260 | - Germany Forschungszulage — refundable → treated as income |
| 261 | - France CIR — refundable post-4-yr → treated as income → no ETR push if claimed timely |
| 262 | - Australia R&DTI refundable offset — treated as income |
| 263 | - Canada SR&ED refundable (CCPC) — treated as income |
| 264 | - Italy super-deduction — non-refundable reduction → reduces Covered Taxes |
| 265 | - Hungary 300% super-deduction — non-refundable → reduces Covered Taxes |
| 266 | - Netherlands WBSO — refundable via payroll withholding → treated as income |
| 267 | |
| 268 | --- |
| 269 | |
| 270 | ## Section 8 — Edge cases and special rules |
| 271 | |
| 272 | ### 8.1 Subcontracted R&D and group transactions |
| 273 | |
| 274 | Most regimes: |
| 275 | - Allow subcontracted R&D at restricted percentage of own R&D (commonly 65-80%) |
| 276 | - Restrict related-party subcontractor R&D to within OECD Modified Nexus Approach principles |
| 277 | - The contracting party (the R&D commissioner) gets the credit; the contractor cannot also claim |
| 278 | |
| 279 | ### 8.2 Grants and subsidised R&D |
| 280 | |
| 281 | Most regimes: |
| 282 | - Reduce the credit base by the amount of grant/state-aid funding received for the same expenditure |
| 283 | - Some allow combining (Italy partially) |
| 284 | |
| 285 | ### 8.3 Foreign R&D performed abroad |
| 286 | |
| 287 | - **UK** (from 2024): generally exclude overseas R&D from claim |
| 288 | - **France**: generally exclude unless within EEA + Norway / Iceland / Liechtenstein |
| 289 | - **US**: include in §41 but §174 forces 15-year amortisation |
| 290 | - **Germany Forschungszulage**: must be performed in Germany; EU sub-contracted possible under conditions |
| 291 | |
| 292 | ### 8.4 Software development |
| 293 | |
| 294 | - **UK**: covered if seeking advance in computer science |
| 295 | - **US**: §41 software covered if functional/process improvement is the goal |
| 296 | - **France**: software R&D yes; routine custom development no |
| 297 | |
| 298 | ### 8.5 Claim windows and amendments |
| 299 | |
| 300 | - **UK**: 2 years post-period-end |
| 301 | - **US**: 3 years from filing deadline; amended returns possible |
| 302 | - **France**: 3 years post-period-end |
| 303 | - **Germany**: 4 years generally |
| 304 | - **Canada SR&ED**: 18 months from period-end |
| 305 | |
| 306 | ### 8.6 Patent box stack |
| 307 | |
| 308 | R&D credit and patent box are independent: |
| 309 | - France: CIR + IP Reduced Rate |
| 310 | - UK: RDEC + Patent Box |
| 311 | - Belgium: R&D investment deduction + Innovation Income Deduction |
| 312 | - Italy: 110% iper-deduzione (now the "patent box replacement") combined with R&D credit |
| 313 | - Netherlands: WBSO payroll relief + Innovation Box (the WBSO is partly a gateway condition for Innovation Box) |
| 314 | |
| 315 | --- |
| 316 | |
| 317 | ## Section 9 — Output specification |
| 318 | |
| 319 | The reviewer brief must include: |
| 320 | |
| 321 | 1. **R&D project inventory** with technical narrative and Frascati test result per project |
| 322 | 2. **Qualifying expenditure schedule** by category and project |
| 323 | 3. **Credit/super-deduction computation** per regime claimed |
| 324 | 4. **Refundable vs non-refundable analysis** and Pillar Two GloBE Income classification |
| 325 | 5. **§174 amortisation schedule** (US claimants) |
| 326 | 6. **Filing deadline calendar** per regime |
| 327 | 7. **Grant / state-aid offset** schedule |
| 328 | 8. **Patent box interaction** — confirm no double-counting; route IP income separately |
| 329 | 9. **Audit risk assessment** — documentation status, prior enquiry history |
| 330 | 10. **Reviewer questions** — open items flagged as [T2] or [T3] |
| 331 | |
| 332 | --- |
| 333 | |
| 334 | ## Section 10 — Self-checks |
| 335 | |
| 336 | - [ ] Frascati criteria applied per project — novelty, creativity, uncertainty, systematic, transferable |
| 337 | - [ ] Qualifying expenditure categories per regime, not assumed by analogy |
| 338 | - [ ] Subcontractor restrictions applied (UK 2024+ overseas restriction) |
| 339 | - [ ] §174 capitalisation modelled separately from §41 credit (US claimants) |
| 340 | - [ ] Refundability tested for Pillar Two QRTC classification |
| 341 | - [ ] Grant / state-aid offset applied to credit base |
| 342 | - [ ] Patent box income excluded from R&D credit base where claimed under patent box |
| 343 | - [ ] Filing deadline plotted with safety margin |
| 344 | - [ ] Additional Information Form / equivalent technical documentation prepared |
| 345 | - [ ] Output flags every [T2]/[T3] item for reviewer judgement |
| 346 | |
| 347 | --- |
| 348 | |
| 349 | ## Section 11 — Prohibitions |
| 350 | |
| 351 | - **Do not** claim R&D credits for routine quality control, market research, social science research, or aesthetic/cosmetic activities — these fail the Frascati novelty test |
| 352 | - **Do not** include grants in the qualifying expenditure base when the regime requires offset |
| 353 | - **Do not** advise overseas subcontracting in the UK without confirming the limited 2024 exception applies |
| 354 | - **Do not** stack R&D credit and patent box on the same IP income — Modified Nexus Approach requires separation |
| 355 | - **Do not** treat the §41 US credit as solving the §174 capitalisation cash-flow timing problem — they are distinct |
| 356 | - **Do not** ignore the OECD Pillar Two refundability classification — non-qualified credits push down the jurisdictional ETR |
| 357 | |
| 358 | --- |
| 359 | |
| 360 | ## Section 12 — Disclaimer |
| 361 | |
| 362 | This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. R&D claims face significant audit scrutiny across virtually every jurisdiction. Every output must be reviewed and signed off by a credentialed practitioner (R&D specialist firms, Big 4 R&D advisory, or local equivalent) before any claim is filed. |
| 363 | |
| 364 | The most up-to-date, verified version of this skill is maintained at [openaccountants.com](https://openaccountants.com). |
| 365 |
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Use this skill whenever a company asks about claiming a research and development tax credit, super-deduction, refundable cash incentive, or grant tied to R&D. Trigger on phrases like "R&D credit", "R&D tax credit", "R&D super-deduction", "RDEC", "merged RDEC", "ERIS", "enhanced R&D intensive support", "SR&ED", "CIR", "Crédit d'Impôt Recherche", "Forschungszulage", "WBSO", "SLIM (Spain)", "credito ricerca", "patent box vs R&D", "R&D in OBBBA", "§174 capitalization", "§41 R&D credit", "JEI / JEU", "China R&D super-deduction", "India R&D §35", "Australia R&DTI", "USDA SBIR", "OECD frascati definition", "qualifying R&D", or any request to compute eligibility, qualifying expenditure, and benefit value of an R&D incentive. Covers 25+ regimes including the post-2024 UK merged RDEC, US §174 capitalisation rules, France CIR, Germany Forschungszulage, Netherlands WBSO and Innovation Box interaction, China 175% super-deduction, India §35, Australia R&DTI, Canada SR&ED. Does NOT cover: patent box (see ip-patent-box-matrix), depreciation of capitalised R&D, grant accounting beyond reference, customs duty on R&D imports. ALWAYS read this skill before assessing R&D credit eligibility or computing a claim.
GLOBALty-2025
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This skill is open source and free to use in any AI agent. Copy it, download it, or clone the repo. If you find an error, report an issue — a licensed accountant will review.