HMRC launched the new Additional Information Form (‘AIF’) for ALL R&D claims filed on or after 8th August 2023.
As a result, I’ve had a lot of companies asking for guidance around the new form, in particular how much information to provide when documenting R&D projects. Whilst it’s still early days and we will learn more as more forms are filed, I’m sharing my experience and suggestions hoping these will help others too:
- If you already prepare a comprehensive R&D report, that in reality is more helpful to HMRC, engage with your CCM and ask that they refer to this foremost. The report is likely to include additional valuable information regarding the claim methodology, competent professionals, detailed cost information, business background and nicely formatted (a.k.a. easy to read) project summaries.
- If you don’t already prepare an R&D report, I would focus only on completing the AIF to minimise duplication. There is no guarantee an R&D report will be read and so you may be wasting valuable time and effort.
- When documenting projects, answer the question and stop. A concise, robust explanation, ideally cross referenced back to the DSIT Guidelines is all that is needed. This should be broadly commensurate with the spend/size of the project (£10m spend deserves more than a single, vague paragraph)!
- Avoid padding out / waffle. Irrelevant content could lead to more questions being asked. An old school Inspector once said to me that if I tell him something, he has to read it, and then (as is human nature) is likely to ask questions!
- Prepare the content in Word for input, review and approval, ready to cut/paste across into the form. Word makes spell checking easier than Excel too. The online form itself is clunky and so hard to share for easy editing and review.
- Take care if you are claiming under both SME and RDEC regimes (eg for internal / funded R&D). The form requires you to document at least 50% of the SME expenditure and 50% of the RDEC expenditure separately, not simply 50% of the total spend.
- If you haven’t provided project details to HMRC for a while, seek an independent review to ensure what you plan to share is fit for purpose and aligns with the legislation and guidelines. It is much easier to get things right first time than deal with a lengthy enquiry caused by clumsy language or unclear explanations.
- December year end companies – do build in time to complete the form – gone are the days of filing a prudent ‘numbers only’ claim at the 11th hour!
Having got used to the form now, I have to say that it’s not as bad as I first thought it would be. It will quickly just become another admin task for us all!
Get in touch to find out more or if you have any questions.
We’re always interested in others’ views and insights too as a collective ‘best practice’ emerges over time.