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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.

  • Rules as at
On this page
  1. Notes
  2. Sources

This page compares what each of the five countries covered on this site requires of a person who prepares research and development (R&D) tax claims for a fee. It sets out whether the adviser must register with the tax authority or another regulator, whether a qualification is required, and how the adviser is authorized to deal with the authority on a client's behalf. Each cell cites the same source as the matching country page. The notes below explain where the table simplifies. The page describes the rules only and makes no recommendation.

This table simplifies each country's rules for comparison. See the country pages for detail and sources. Last reviewed pending.

Country Registration to act for a fee Qualification required How the adviser deals with the authority for a client
United States A preparer tax identification number (PTIN) is required for anyone who prepares federal returns for compensation1Source 1Internal Revenue Service, PTIN requirements for tax return preparers (page last reviewed or updated 16 October 2025). https://www.irs.gov/tax-professionals/ptin-requirements-for-tax-return-preparers (accessed 11 October 2026). None for a PTIN; no examination2Source 2Internal Revenue Service, Understanding tax return preparer credentials and qualifications, sections "Unlimited representation rights", "Limited representation rights", "Annual filing season program participants" and "PTIN holders" (page last reviewed or updated 29 January 2026). https://www.irs.gov/tax-professionals/understanding-tax-return-preparer-credentials-and-qualifications (accessed 11 October 2026). Enrolled agents, CPAs and attorneys have unlimited representation rights; others are limited or have none2Source 2Internal Revenue Service, Understanding tax return preparer credentials and qualifications, sections "Unlimited representation rights", "Limited representation rights", "Annual filing season program participants" and "PTIN holders" (page last reviewed or updated 29 January 2026). https://www.irs.gov/tax-professionals/understanding-tax-return-preparer-credentials-and-qualifications (accessed 11 October 2026).
United Kingdom Registration with HMRC under the Finance Act 2026 for paid advisers who interact with HMRC for clients, with exceptions3Source 3HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).4Source 4HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026). Not among the registration conditions HMRC lists5Source 5HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026). An agent needs an agent services account to submit the additional information form6Source 6HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).
Ireland A Tax Advisor Identification Number (TAIN) is needed to represent a client; Revenue operates no approval system7Source 7Revenue Commissioners, Tax and Duty Manual Part 37-00-04b, Guidelines for Agents or Advisors acting on behalf of taxpayers (last reviewed September 2026), sections 1, 2, 4, 5, 12 and 21. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-37/37-00-04b.pdf (accessed 11 October 2026). None in the sources reviewed7Source 7Revenue Commissioners, Tax and Duty Manual Part 37-00-04b, Guidelines for Agents or Advisors acting on behalf of taxpayers (last reviewed September 2026), sections 1, 2, 4, 5, 12 and 21. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-37/37-00-04b.pdf (accessed 11 October 2026).8Source 8Revenue Commissioners, Application for a TAIN, Tax Agent Identification Number / Transaction Advisor Identification Number, form and declaration. https://www.revenue.ie/en/starting-a-business/documents/application-form-tain.pdf (accessed 11 October 2026). Agent link to the client, quoting the agent's TAIN7Source 7Revenue Commissioners, Tax and Duty Manual Part 37-00-04b, Guidelines for Agents or Advisors acting on behalf of taxpayers (last reviewed September 2026), sections 1, 2, 4, 5, 12 and 21. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-37/37-00-04b.pdf (accessed 11 October 2026).
Canada No registration requirement for SR&ED claim preparers identified; the preparer must be named on the claim9Source 9Canada Revenue Agency, Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, T661 E (26), Part 9, Claim preparer information, and Part 10, Certification, line 175. https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t661/t661-26e.pdf (accessed 11 October 2026). None identified10Source 10Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsection 162(5.3), definitions of "claim preparer", "claim preparer information" and "SR&ED form". https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-162.html (accessed 11 October 2026). Authorization as a representative, for example through Represent a Client11Source 11Canada Revenue Agency, About Represent a Client. https://www.canada.ca/en/revenue-agency/services/e-services/represent-a-client/about-represent-a-client.html (accessed 11 October 2026).12Source 12Canada Revenue Agency, Levels and scope of authorization that you can give representatives of your business. https://www.canada.ca/en/revenue-agency/services/tax/representative-authorization/access/levels-scope.html (accessed 11 October 2026).
Singapore No statutory registration or licensing scheme for tax advisers identified13Source 13Inland Revenue Authority of Singapore, Enhanced IRAS-tax agent Relationship Framework (last updated 28 January 2026), section "Accreditation for tax professionals". https://www.iras.gov.sg/quick-links/tax-agents/iras-tax-agent-relationship (accessed 11 October 2026).14Source 14Inland Revenue Authority of Singapore, Partnership with tax agents (last updated 27 March 2026), sections "Enhanced IRAS-Tax Agent Relationship", "Expectations of IRAS and tax agents under the Enhanced IRAS-Tax Agent Relationship Framework" and "Consequences of non-compliance by tax agents". https://www.iras.gov.sg/who-we-are/what-we-do/public-engagement/partnership-with-tax-agents (accessed 11 October 2026). None by law; voluntary accreditation by SCTP13Source 13Inland Revenue Authority of Singapore, Enhanced IRAS-tax agent Relationship Framework (last updated 28 January 2026), section "Accreditation for tax professionals". https://www.iras.gov.sg/quick-links/tax-agents/iras-tax-agent-relationship (accessed 11 October 2026). The company authorizes the adviser in Corppass as a "Preparer" or an "Approver"15Source 15Inland Revenue Authority of Singapore, Frequently Asked Questions (FAQs) on Filing of Form C-S/ Form C-S (Lite) (updated 15 May 2026), question 3. https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/faqs---file-form-c-s.pdf?sfvrsn=7b435b8f_52 (accessed 11 October 2026).

Notes

United States. Regulations of 2011 that required paid preparers to register were enjoined after Loving v. IRS, and the December 2024 proposal would remove the remaining provisions on registered tax return preparers.16Source 16Treasury Department and Internal Revenue Service, Regulations Governing Practice Before the Internal Revenue Service, notice of proposed rulemaking, 89 FR 104915 (26 December 2024), summary and Background part A. https://www.federalregister.gov/documents/2024/12/26/2024-29371/regulations-governing-practice-before-the-internal-revenue-service (accessed 11 October 2026). For 2026 the IRS lists a fee of $18.75 for a new PTIN or a renewal.1Source 1Internal Revenue Service, PTIN requirements for tax return preparers (page last reviewed or updated 16 October 2025). https://www.irs.gov/tax-professionals/ptin-requirements-for-tax-return-preparers (accessed 11 October 2026). The Form 6765 instructions set no separate credential or registration requirement for people who prepare research credit calculations.17Source 17Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), read in full. https://www.irs.gov/instructions/i6765 (accessed 11 October 2026).

United Kingdom. Registration depends on interacting with HMRC about a client's tax affairs and being paid for that service, so an adviser that advises on a claim but does not interact with HMRC is outside it.4Source 4HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026). Exceptions include giving tax advice for free and representing a client in appeals to a court or tribunal.3Source 3HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026). Sanctions include suspension, financial penalties for prohibited interactions and publication.18Source 18HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026).

Ireland. Revenue states that a TAIN is not an approval or endorsement of an agent's conduct, experience or abilities, and the application form says a TAIN may be withdrawn at any time.7Source 7Revenue Commissioners, Tax and Duty Manual Part 37-00-04b, Guidelines for Agents or Advisors acting on behalf of taxpayers (last reviewed September 2026), sections 1, 2, 4, 5, 12 and 21. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-37/37-00-04b.pdf (accessed 11 October 2026).8Source 8Revenue Commissioners, Application for a TAIN, Tax Agent Identification Number / Transaction Advisor Identification Number, form and declaration. https://www.revenue.ie/en/starting-a-business/documents/application-form-tain.pdf (accessed 11 October 2026). The country page found no qualification, examination or membership requirement in the sources it reviewed.

Canada. The Income Tax Act defines a claim preparer by reference to accepting consideration, not a designation or license.10Source 10Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsection 162(5.3), definitions of "claim preparer", "claim preparer information" and "SR&ED form". https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-162.html (accessed 11 October 2026). The CRA does not describe Represent a Client registration as a license to prepare SR&ED claims.11Source 11Canada Revenue Agency, About Represent a Client. https://www.canada.ca/en/revenue-agency/services/e-services/represent-a-client/about-represent-a-client.html (accessed 11 October 2026). Whether any province regulates who may prepare R&D tax credit claims was not identified.

Singapore. The country page identified no statutory registration scheme and no statutory power for IRAS to bar a person from acting as a tax agent. The sources reviewed do not state which Corppass role is needed to submit an EIS cash payout application for a business.

Sources

  1. Internal Revenue Service, PTIN requirements for tax return preparers (page last reviewed or updated 16 October 2025). https://www.irs.gov/tax-professionals/ptin-requirements-for-tax-return-preparers (accessed 11 October 2026).   Back
  2. Internal Revenue Service, Understanding tax return preparer credentials and qualifications, sections "Unlimited representation rights", "Limited representation rights", "Annual filing season program participants" and "PTIN holders" (page last reviewed or updated 29 January 2026). https://www.irs.gov/tax-professionals/understanding-tax-return-preparer-credentials-and-qualifications (accessed 11 October 2026).   Back
  3. HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).   Back
  4. HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026).   Back
  5. HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026).  Back
  6. HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).  Back
  7. Revenue Commissioners, Tax and Duty Manual Part 37-00-04b, Guidelines for Agents or Advisors acting on behalf of taxpayers (last reviewed September 2026), sections 1, 2, 4, 5, 12 and 21. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-37/37-00-04b.pdf (accessed 11 October 2026).     Back
  8. Revenue Commissioners, Application for a TAIN, Tax Agent Identification Number / Transaction Advisor Identification Number, form and declaration. https://www.revenue.ie/en/starting-a-business/documents/application-form-tain.pdf (accessed 11 October 2026).   Back
  9. Canada Revenue Agency, Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, T661 E (26), Part 9, Claim preparer information, and Part 10, Certification, line 175. https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t661/t661-26e.pdf (accessed 11 October 2026).  Back
  10. Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsection 162(5.3), definitions of "claim preparer", "claim preparer information" and "SR&ED form". https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-162.html (accessed 11 October 2026).   Back
  11. Canada Revenue Agency, About Represent a Client. https://www.canada.ca/en/revenue-agency/services/e-services/represent-a-client/about-represent-a-client.html (accessed 11 October 2026).   Back
  12. Canada Revenue Agency, Levels and scope of authorization that you can give representatives of your business. https://www.canada.ca/en/revenue-agency/services/tax/representative-authorization/access/levels-scope.html (accessed 11 October 2026).  Back
  13. Inland Revenue Authority of Singapore, Enhanced IRAS-tax agent Relationship Framework (last updated 28 January 2026), section "Accreditation for tax professionals". https://www.iras.gov.sg/quick-links/tax-agents/iras-tax-agent-relationship (accessed 11 October 2026).   Back
  14. Inland Revenue Authority of Singapore, Partnership with tax agents (last updated 27 March 2026), sections "Enhanced IRAS-Tax Agent Relationship", "Expectations of IRAS and tax agents under the Enhanced IRAS-Tax Agent Relationship Framework" and "Consequences of non-compliance by tax agents". https://www.iras.gov.sg/who-we-are/what-we-do/public-engagement/partnership-with-tax-agents (accessed 11 October 2026).  Back
  15. Inland Revenue Authority of Singapore, Frequently Asked Questions (FAQs) on Filing of Form C-S/ Form C-S (Lite) (updated 15 May 2026), question 3. https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/faqs---file-form-c-s.pdf?sfvrsn=7b435b8f_52 (accessed 11 October 2026).  Back
  16. Treasury Department and Internal Revenue Service, Regulations Governing Practice Before the Internal Revenue Service, notice of proposed rulemaking, 89 FR 104915 (26 December 2024), summary and Background part A. https://www.federalregister.gov/documents/2024/12/26/2024-29371/regulations-governing-practice-before-the-internal-revenue-service (accessed 11 October 2026).  Back
  17. Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), read in full. https://www.irs.gov/instructions/i6765 (accessed 11 October 2026).  Back
  18. HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026).  Back