Ian Davie
Senior Consultant
After several years of remote meetings, the most recent Research & Development Communication Forum (RDCF) marked a significant shift, returning to an in-person format for a limited number of attendees. With registrations filling up quickly, only those who acted fast were able to attend in person, while others joined via live stream. This hybrid setup aimed to restore a more collaborative and engaging environment, something that had been lacking in recent virtual-only sessions. This was the first RDCF held face-to-face since before the COVID-19 pandemic.
The date and location of the forum carried symbolic weight. Held on May 6th, just two days before VE Day, the event took place in the historic Churchill Room at HMRC’s Parliament Street office. This very room is where Winston Churchill once stood on the balcony to declare Victory in Europe nearly 80 years ago. Just a few paces down the road, the Cenotaph was draped in flags to mark the occasion.
The decision to return to an in-person format was intended to help HMRC better gauge the atmosphere in the room and encourage genuine two-way communication. Previous RDCF events had become somewhat one-sided, with HMRC presenting to a passive online audience and addressing only selected questions. This gave no opportunity for feedback, discussion, or comment from the attendees. The in-person setting allowed for more meaningful dialogue and personal interaction between HMRC and attendees, many of whom had previously only connected through emails or video calls.
The topics for the May 2025 RDCF were:
Advance Clearance is envisaged to replace the current Advance Assurance scheme for R&D tax credits. The present scheme is underutilised, with it not being used a great deal. It largely targets smaller companies that have not claimed before. I believe that companies are put off by the fear that HMRC will reject the R&D activities at the early stages of the R&D process, rather than allowing them to present their R&D at the end of each accounting period.
The Advance Clearance seems to take a different approach. Unlike Advance Assurance, which is largely passive, Advance Clearance could become mandatory for high-risk sectors or large-scale projects, while remaining voluntary for high-growth businesses. The aim is to reduce errors and fraud, improve certainty for businesses, and enhance the customer experience.
As a result of the heavy-handed approach HMRC has taken with R&D compliance checks, many companies are growing cautious about engaging in UK-based R&D. During the session, I raised the question of whether this initiative could help reassure companies considering UK investment for R&D, particularly those that have not yet registered as an overseas company. This apparently was an excellent question! It appeared they had not thought of that.
As anticipated, HMRC provided an update on its performance against Service Level Agreements (SLAs). The target remains to process 85% of R&D claims within 40 days, including during peak periods such as December and March. HMRC reiterated its commitment to meeting this goal by allocating additional resources as needed during busier times.
Over the past year, HMRC established a dedicated team to work with R&D agents, aiming to improve compliance in the claims submitted on behalf of their clients. So far, 17 agents have completed this re-education programme, including one attendee at the forum who noted it had been a valuable experience. This programme is due to be doubled in size with another team set up to take on a similar cohort, bringing the total capacity to approximately 34 agents per year. This shows a clear commitment from HMRC to working collaboratively with agents to raise the standard of submissions.
The Additional Information Form (AIF) is now a critical and mandatory element of any R&D claim, with claims being rejected if there is no AIF. Those with inaccurate details on the AIF can also result in compliance checks or an automatic rejection. Common mistakes include mismatched accounting periods or incorrect Unique Taxpayer References (UTRs). Fortunately, these issues can often be resolved with a corrected AIF resubmission, but the delays can be costly. TBAT Innovation has seen a notable rise in companies seeking help at this stage, highlighting the need for accuracy and care when completing the Additional Information Form and the Claim Notification Form.
HMRC has now opened recruitment for 6 positions on the expert advisory panel, covering key sectors such as tech development (slightly vague!), AI, advanced manufacturing, and life sciences. There is an expectation that each member will contribute 40 hours per year.
However, questions remain about the panel’s practical impact. I am not certain if this will help or hinder HMRC and companies looking to make claims. Each of these sectors is broad in scope, and the interpretation of what constitutes R&D may vary significantly depending on whether the experts come from academia or industry. This could lead to inconsistencies in guidance or expectations.
HMRC expressed a genuine interest in hearing about real challenges within the R&D claims process. There is a desire to improve the process, HMRC’s efficiency, understanding of R&D, and to better manage the R&D claims being presented to them.
TBAT Innovation has engaged with HMRC Compliance Managers in specific cases and has received support where appropriate. We will continue to share examples where HMRC may be creating unnecessary obstacles or are stepping outside of the rules. However, such instances remain rare, as the majority of claims and compliance checks will take their normal course of action.
The May 2025 RDCF marked a welcome return to in-person engagement, offering a more open and collaborative space for dialogue between HMRC and the R&D tax credit community. With a packed agenda covering policy developments, operational updates, and compliance measures, the session took a look at HMRC’s current direction and ongoing efforts to improve the R&D claims process. From the proposed Advance Clearance scheme to the expansion of agent education programmes and the recruitment of an expert advisory panel, it is clear that HMRC is actively seeking to refine its approach to R&D tax relief. The introduction of mandatory documentation requirements such as the AIF and CNF reinforces the need for accuracy and transparency in every claim.
HMRC’s openness to feedback is encouraging, particularly as businesses continue to navigate a complex and shifting compliance environment. At TBAT Innovation, we’ll continue to work closely with HMRC where we can, supporting our clients through any changes, and making sure that genuine innovation isn’t held back by unnecessary complexity. We’ll keep a close eye on how things develop and will share updates as more changes and initiatives are introduced.
If you would like to discuss anything that was raised in the RDCF, you can book a 1-2-1 consultation to chat with me today.
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