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Side by side tables of the rules on research and development tax claims and the advisers who prepare them, one topic across five countries or two countries across several topics.
These pages put the rules from the five countries covered on this site side by side. The topic tables take one subject, such as contingent fee rules, adviser registration or penalties, and set out how each country deals with it. The country pair pages compare the United States with another country, or two other countries with each other, across fees, preparers and claim integrity. Every cell is drawn from the matching country page and cites the same official source, and each table shows the date its rules are stated as at. A table simplifies, so each comparison has notes and links to the full country pages. The comparisons describe the rules only. They do not rank countries or recommend changes outside the United States.
Comparisons
Each shows the countries it covers and when it was last checked.
- Contingent fee rules by country
How the five countries covered on this site treat contingent (success) fees for preparing research and development tax claims, whether the claim reports how the adviser is paid, and the main related rules on fees and payments.
- US
- UK
- IE
- CA
- SG
- Professional body rules by country
What the main accounting and tax professional codes in the five countries covered on this site say about contingent fees for tax work, and who those codes bind.
- US
- UK
- IE
- CA
- SG
- Adviser registration by country
Whether an adviser who prepares research and development tax claims for a fee must register with the tax authority or hold a qualification in each of the five countries covered on this site, and how the adviser is authorized to deal with the authority for a client.
- US
- UK
- IE
- CA
- SG
- Preparer identification by country
Whether a research and development tax claim must name the adviser who prepared it in each of the five countries covered on this site, where that happens, and whether the adviser's fee is reported.
- US
- UK
- IE
- CA
- SG
- Claim integrity measures by country
The advance notification, approval, claim information and validity rules that each of the five countries covered on this site applies to research and development tax claims.
- US
- UK
- IE
- CA
- SG
- Penalties by country
The main penalties that can apply to an incorrect research and development tax claim in each of the five countries covered on this site, for the claimant and for the advisers who prepare or promote claims.
- US
- UK
- IE
- CA
- SG
- Reviews and audits by country
Who reviews research and development tax claims in each of the five countries covered on this site, how claims are selected for review, and how long the authority generally has to reassess.
- US
- UK
- IE
- CA
- SG
- Disputes and appeals by country
How a claimant in each of the five countries covered on this site can challenge a decision that reduces a research and development tax claim, which tribunal or court hears the dispute, and the first time limit that applies.
- US
- UK
- IE
- CA
- SG
- US vs UK
How the United States and the United Kingdom compare on adviser fees, the people who prepare research and development claims, and the checks on those claims, set out side by side with official sources.
- USUnited States
- UKUnited Kingdom
- US vs Canada
How the United States and Canada compare on adviser fees, the people who prepare research claims, and the checks on those claims, set out side by side with official sources.
- USUnited States
- CACanada
- US vs Ireland
How the United States and Ireland compare on adviser fees, the people who prepare research and development claims, and the checks on those claims, set out side by side with official sources.
- USUnited States
- IEIreland
- US vs Singapore
How the United States and Singapore compare on adviser fees, the people who prepare research and development claims, and the checks on those claims, set out side by side with official sources.
- USUnited States
- SGSingapore
- UK vs Ireland
How the United Kingdom and Ireland compare on adviser fees, the people who prepare research and development claims, and the checks on those claims, set out side by side with official sources.
- UKUnited Kingdom
- IEIreland
- Canada vs UK
How Canada and the United Kingdom compare on adviser fees, the people who prepare research and development claims, and the checks on those claims, set out side by side with official sources.
- CACanada
- UKUnited Kingdom
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Registration is handled by Swanson Reed, the publisher of this site, on its own booking page.