Yasmin Dalton
Consultant
HMRC has released a revised version of its practice note CIRD80525, which outlines the approach to handling Research and Development (R&D) tax relief claims. While the core aim of supporting innovation and ensuring fairness in claim processing remains, the update brings several key changes that businesses and advisers should be aware of.
One of the most notable changes is the shift in departmental responsibility. Previously, R&D claims were overseen by dedicated specialist R&D units. These units, established in 2006, played a central role in processing claims and advising companies on technical and procedural matters. The updated guidance, however, reflects HMRC’s internal restructuring, transferring responsibility to the Individuals and Small Business Compliance (ISBC) and Wealthy and Mid-sized Business Compliance (WMBC) teams. This aligns with HMRC’s broader move towards streamlining services and reducing departmental silos.
Alongside this structural change, the updated guidance modernises the language used throughout. For instance, references to the now-defunct Department for Business Innovation and Skills have been replaced with the Department for Science, Innovation and Technology. Additionally, the updated document places more emphasis on process and standardisation, using terms such as “Officers” rather than “specialist advisers” or “staff.” Whilst these are not key changes, they are still important to note.
A significant addition to the updated guidance is the introduction of new procedural requirements before making a claim. Companies submitting their first claim, amending a return to include a claim, or claiming for an accounting period beginning on or after 1 April 2023, are now required to file a Claim Notification. Furthermore, all claimants must now submit an Additional Information Form (AIF) for every accounting period in which a claim is made. This form collects key details about the R&D activities and associated costs and is intended to provide officers with more information up front to support risk assessment and claim validation. Guidance on how to complete this form is now available on Gov.uk, or you can contact our team at TBAT for assistance.
The handling of R&D tax credit payments remains broadly similar, with HMRC reaffirming its goal of paying 85% of payable tax credits within 40 days of receipt or making contact within the same period. However, this is no longer guaranteed in all cases. The updated document clarifies that this target may not apply in exceptional circumstances, such as when claims are submitted non-electronically or lack complete bank details. The commitment to open an enquiry within 60 days if a payment is withheld also remains, but with firmer emphasis that these operational aims do not replace statutory time limits for enquiries into Corporation Tax returns.
In terms of case handling, smaller companies will generally have their corporation tax matters managed by a dedicated officer or team within ISBC or WMBC. For larger businesses or groups, claims will continue to be managed under the existing structures involving Customer Compliance Managers (CCMs) or Customer Coordinators (CCs). However, the updated guidance no longer guarantees the provision of named officer contact details, suggesting a more centralised and less personalised approach.
While the enquiry process itself is largely unchanged, some procedural details have been refined. HMRC officers may still request discussions with a company’s management and technical teams to assess whether R&D criteria have been correctly applied. They will seek necessary records early in the process and aim to keep requests proportionate, but reserve the right to ask for additional details if new issues arise. Notably, the updated version omits any reference to the possibility of interim payments being made while an enquiry is ongoing, suggesting a firmer stance on withholding relief until enquiries are resolved.
Finally, communication protocols have also been adjusted. Previously, companies were advised to contact the head of the relevant R&D unit if they felt uninformed during an enquiry. Now, the guidance instructs companies to use the contact details provided in the most recent enquiry correspondence, further reinforcing a more standardised communication model.
Overall, while the updated guidance in CIRD80525 retains HMRC’s commitment to being supportive and balanced in its approach to R&D claims, it introduces more formalised procedures, clearer compliance expectations, and aligns with broader changes to HMRC’s internal structure. Businesses engaging with R&D tax relief are strongly advised to familiarise themselves with the new requirements, especially the Additional Information Form, to ensure claims are not delayed or denied due to non-compliance.
Read the full guidance: CIRD80525 – Practice note for ISBC and WMBC – HMRC internal manual – GOV.UK
Please get in touch with our TBAT team today if you would like any help understanding the information provided in the CIRD80525 manual.
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