R&D tax relief – new claim notification rules explained

Businesses claiming Research & Development (R&D) tax relief should be aware of an important new HMRC requirement.  As part of its efforts to reduce errors and fraud, HMRC has introduced a mandatory claim notification process for certain businesses. Missing the notification deadline could mean losing the right to claim R&D tax relief altogether.

Who needs to notify HMRC?

The notification rules apply to accounting periods beginning on or after 1 April 2023.

A company must submit a claim notification if it is:

• claiming R&D tax relief for the first time
• making a claim where its last successful claim was submitted more than three years before the end of the current claim notification period
• making a claim where a previous claim was made within the last three years but does not meet HMRC's exemption criteria.

For example, a company with a 31 March 2026 year end, must submit its notification to HMRC by 30 September 2026.

If the notification is not submitted on time, the company will be unable to claim R&D tax relief for that accounting period.

What Is the three year exemption?

Businesses that have claimed R&D relief before, may not need to submit a notification if their previous claim falls within the relevant three year period.

To work this out, directors will have to identify the final day of the claim notification period (six months after your accounting period ends) and count back three years. If your previous qualifying claim falls within that period, you may be exempt.  However, transitional rules may apply depending on how the earlier claim was submitted.

What information Is required?

The online notification requires:

• the company's Unique Taxpayer Reference (UTR)
• details of the senior person responsible for the R&D claim, such as a director
• details of any agent acting on the company's behalf
• the accounting period and period of account dates
• a summary of the planned R&D activities

The notification can be submitted by either the company or its agent using a government gateway account or email address. HMRC will then issue a reference number, which should be retained for your records.

Making your claim

Submitting the notification does not complete the claim itself. When submitting the company tax return, you must:

• mark box 656 with an "X" to confirm a claim notification has been submitted
• submit the required additional information form alongside the R&D claim.

Don't miss the deadline

The notification requirement is now a crucial part of the R&D claims process. If your business is required to notify HMRC but fails to do so within the six month deadline, your claim will be refused, even if your R&D activities would otherwise qualify for relief.

If you're considering making an R&D tax relief claim and have any questions do get in touch with your Swindells partner who will be able to help you further.