R&D claim - 'additional information form'

Does an SME making R&D claim need to submit 'additional information form'?

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An SME company involved in technology R&D projects submitted CT600 for the financial year ended 31 March 2023. CT600 included R&D claim. HMRC rejected R&D claim because they have not submitted 'additional information form'.

The requirement for 'additional information form' says 'From 8 August 2023 you must submit an additional information form to support your claim.'

Could someone please clarify how this new requirement works?

First of all, the accounting period end is before 8 August 2023. Does this requirement applies to claims made for periods ended before 8 August 2023? 

Secondly, I could not find a PDF form as such, e.g. like CT600, on www.gov.uk. The company uses Andica software to submit Corporation tax return. Does anyone know if all software applications were updated to include this new 'additional information form' introduced from 8 August 2023? I am surprised the software did not prompt the person completing tax return to complete 'additional information form'.

Finally, since the deadline for Tax return was 31 March 2024, would HMRC reconcider its decision if 'additional information form' is submitted now? HMRC letter says 'you cannot appeal against this notice'. Has anyone had experience of HMRC reconsidering R&D claim because 'additional information form' is very new requirement? Or it will be a waste of time and it is better to include the lost R&D costs into the next year's R&D claim? I know from 1 April 2023 SME R&D relief was reduced but there is no precedent that HMRC changed their decision after late submission of 'additional information form' then it may not worth to spend time on it.

Thanks in advance for help.

Replies (8)

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By Paul Crowley
07th Apr 2024 17:22

R & D is a specialist area. We get emails on a very regular basis from such specialists. If this is not a specialist area for you, contact one of those.

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By Matrix
07th Apr 2024 18:04

Yes it applies to any claim submitted after August 2023. My software has a box to tick to say the form has been submitted. It is submitted through HMRC online, it is fairly straightforward, there were some posts on here at the time.

I don’t think you can include this claim the following year if it has been rejected.

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Replying to Matrix:
By Ruddles
07th Apr 2024 18:14

Matrix wrote:

I don’t think you can include this claim the following year if it has been rejected.


Correct - company can claim relief only for expenditure incurred in the relevant accounting period. As suggested below the solution is to file an AIF now and then an ‘amended’ CT600.
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By jamesjcrylatt
07th Apr 2024 18:05

You just need to submit an AIF and then resubmit the CT600 as an amendment:
https://www.gov.uk/guidance/submit-detailed-information-before-you-claim...

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By rmillaree
07th Apr 2024 20:19

Does anyone know if all software applications were updated to include this new 'additional information form' introduced from 8 August 2023?

you can submit the additional information form via your agent services account - link below.

https://www.gov.uk/guidance/submit-detailed-information-before-you-claim...

I am surprised the software did not prompt the person completing tax return to complete 'additional information form'.

hmmmm not sure why you would be surprised than hmrc wouldnt actively make it easy and foolproof - surely you know hmrc by now !!

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Replying to rmillaree:
By Ruddles
07th Apr 2024 20:29

rmillaree wrote:

surely you know hmrc by now !!


And anyone advising on R&D claims should know the rules.
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Replying to rmillaree:
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By Matrix
07th Apr 2024 20:55

You would expect so as it is required in box 656.

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By FactChecker
07th Apr 2024 21:16

The 'additional information' is not really a "very new requirement" ... it was always part of what should have been supplied (as best practice), as I used to do nearly two decades ago.
HMRC merely tightened up this one specific aspect recently - and trailed that it was coming for quite some time by their standards (so anyone with experience would've known).

And frankly the concept of a 'form' is still far too simplistic.
Given the amount of both disaggregated data and supporting text (of essay length) that they are entitled to demand, the form just provides a 'no-effort' hurdle with which to trip up some claims ... a hurdle which OP's client has obligingly failed to clear.

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