New HMRC R&D pre-notification form

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For accounting periods starting on or after April 1, 2023, HMRC R&D pre-notification is now required for businesses intending to make an R&D tax claim.

Pre-notification requirements are part of HMRC’s latest measures to reduce non-compliance in R&D tax relief claims. Together with the recently introduced Additional Information Form (mandatory for all R&D claims submitted after August 8, 2023), these steps aim to improve claim accuracy and reduce fraud.

The pre-notification must be submitted using a digital form. It’s important to understand who needs to submit the form, when it needs to be submitted, what information you will need, and what happens next.

Who is required to submit a HMRC pre-notification form?

The pre-notification form for R&D tax relief claims is required for certain businesses under HMRC’s new rules for accounting periods beginning on or after April 1, 2023. This form must be submitted if:

The company is claiming R&D tax relief for the first time: Companies making an initial R&D claim need to notify HMRC ahead of their claim.
The company has not made an R&D claim within the past three years: If a company last claimed R&D tax relief more than three years before the current claim notification period’s end, they need to pre-notify HMRC.

Who can submit the notification form?

To complete the form, you must either be a representative, or an agent authorised to act on the company’s behalf. The form is submitted digitally through a Government Gateway ID. After submitting, HMRC will send you a receipt with a reference number, which you’ll need should you need to contact them. Be sure to save a copy of your submitted form for your records, as HMRC won’t provide a copy.

Understanding the Claim Notification Period

When it comes to R&D tax relief claims, submitting the pre-notification form within the “claim notification period” is crucial. Missing this window will render your R&D tax relief claim invalid. Here’s what you need to know about determining your specific claim notification period.

HMRC pre-notification form. Someone filling out online documents

What is the Claim Notification Period?

Your claim notification period is based on your:

Period of account – the span covered by your company’s financial statements (which may extend beyond 12 months)
Accounting period(s) within that period of account – these are the intervals covered by your Company Tax Return (cannot exceed 12 months)

How to Determine Your Claim Notification Period

The claim notification period starts on the first day of the period of account and ends six months after it concludes.

For a period of account of 12 months or less: Your accounting period will likely align with your period of account.
For a period of account longer than 12 months: This will include multiple accounting periods, but the claim notification period will be the same for all of them.

If you’re claiming R&D tax relief for the first time, you must submit the claim notification form within the designated claim notification period. For claims related to a period of account lasting more than 12 months, you only need to submit the form for one of the accounting periods.

If you’ve previously claimed R&D tax relief and it was within three years of the last date of your claim notification period, there’s no need to submit the form again, unless any of the following exceptions apply:

HMRC rejected your previous claim by removing it from your Company Tax Return.
You amended your tax return for a period before April 1, 2023, and the amendment was received by HMRC on or after April 1, 2023.

If your last claim was made more than three years ago or any of the above exceptions apply, you will need to either submit the claim notification form by the last date of the claim notification period or send the R&D tax relief claim via your Company Tax Return (or an amendment) so that it’s received by HMRC before the period’s deadline.

By understanding these timelines, you can ensure your R&D tax relief claim remains valid and compliant with HMRC requirements.

If your client misses the pre-notification deadline for a prospective R&D claim, their claim will be automatically rejected by HMRC, with no exceptions. Any missed deadlines or miscalculations regarding the exemption period will result in a complete loss of their R&D tax relief claim.

What will I need to complete the form?

To complete the R&D pre-notification form, you’ll need the following information:

Company’s UTR (Unique Taxpayer Reference)
Contact details of the company’s senior officer responsible for the R&D claim
Contact information for all agents involved
Accounting period dates
A detailed summary of planned R&D activities that demonstrates the project meets HMRC’s standard definition of R&D

For full guidance on the HMRC pre-notification from please click here, if you have any questions or would like to speak to our Senior R&D Tax Consultant, please get in touch today.

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