A company that intends to claim R&D tax relief for an accounting period may be required to give notice to HMRC before the end of the claim notification period. This is in addition to submitting an additional information form and making the claim in the company’s corporation tax return. If the deadline for submitting the claim notification is missed, the company’s claim for R&D tax relief will be invalid.

Requirement to give advance notice 

The requirement applies to: 

• companies that have not made a claim previously; and
• companies that last made a claim more than three years before the end of the claim notification period.  

Claims rejected by HMRC are not taken into account. In addition, a claim that meets the following conditions is excluded:

• it is for an accounting period beginning before 1 April 2023; and
• it was made by amending the tax return on or after 1 April 2023. 

Determining the claim notification period 

The claim notification period: 

• starts on the first day of the company’s period of account; and 
• ends six months after the end of the period of account  

The company’s period of account is the period covered by its financial statements. Where the period of account is 12 months or less, it will be the same as the company’s accounting period. Where it exceeds 12 months, it will cover two or more accounting periods. In this case, the claim notification period is the same for both accounting periods.  The company only needs to submit the form for one of the accounting periods. 

Information to include 

HMRC’s guidance sets out the information needed to complete the form. This includes the company’s unique taxpayer reference and the accounting period start and end dates. If these details do not match the company’s tax return, HMRC will remove the claim from the tax return.  

The company can make a written representation to HMRC if it disagrees with HMRC’s decision to correct its return. However, HMRC rejects representations where the UTR or the accounting period start and end dates were incorrect. HMRC says that it is reviewing its procedures and will provide an update in due course.  

Error in HMRC’s guidance 

Between 8 September 2024 and 17 October 2024, HMRC’s guidance at CIRD183000 contained incorrect information.  

As a result of this error, HMRC says that it will allow claims without a claim notification form where: 

• the company made a valid claim in an amendment to a return for an accounting period beginning before 1 April 2023, which was submitted to HMRC between 1 April 2023 and 30 November 2024; and
• the accounting period for which a claim notification form was not delivered, but ought to have been, had a claim notification period ending between 8 September 2024 and 30 November 2024.  

The company or the agent must contact HMRC by email at randd.policy@hmrc.gov.uk. The email should have the subject line ‘CIRD183000 notification’ and provide the following information: 

• evidence of authority to act on behalf of the company;
• the company’s name and UTR; 
• the date the amended return containing the claim, which the company was relying on to meet the claim notification requirement, was submitted;
• the accounting period that was not notified as a result of the incorrect guidance; and
• the period of account which that accounting period formed a part of.

Further information

• TAXguide 07/23: Making R&D claims | ICAEW