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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.

On this page
  1. Notes
  2. Sources

Each of the five countries covered on this site checks research and development (R&D) tax claims in its own way. This page compares three features of each system: whether the claimant must notify the authority or obtain approval before it claims, what information goes in with the claim, and what happens if a requirement is not met. Each cell cites the same source as the matching country page. Records rules, payment controls and other measures are summarized in the notes below. 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 Advance notice or approval Information with the claim If a requirement is not met
United States Not required1Source 1Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), Purpose of Form, What's New, Section E, "Requirements To Complete Section G", "How To Complete Section G", "Statistical Sampling", "Column 49(f)" and "Research Credit Claims on Amended Returns". https://www.irs.gov/instructions/i6765 (accessed 11 October 2026).2Source 2Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 4, 7 and 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026). Form 6765, and specified information with research credit refund claims1Source 1Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), Purpose of Form, What's New, Section E, "Requirements To Complete Section G", "How To Complete Section G", "Statistical Sampling", "Column 49(f)" and "Research Credit Claims on Amended Returns". https://www.irs.gov/instructions/i6765 (accessed 11 October 2026).2Source 2Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 4, 7 and 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026). A deficient refund claim is rejected if the missing information is not supplied within 45 days2Source 2Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 4, 7 and 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).
United Kingdom Claim notification for first-time claimants and companies with no claim in the last three years3Source 3HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (last updated 31 October 2024), sections "Who needs to submit the form", "When to submit the form", "Working out your claim notification period" and "What information you'll need". https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026). Additional information form for every claim made on or after 8 August 20234Source 4HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD182000, "R&D Tax Reliefs: reformed reliefs: claims process: additional information form" (updated 25 August 2026), sections "Statutory framework", "What information is required" and "Failure to provide complete or proper responses". https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird182000 (accessed 11 October 2026). The claim is invalid3Source 3HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (last updated 31 October 2024), sections "Who needs to submit the form", "When to submit the form", "Working out your claim notification period" and "What information you'll need". https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).4Source 4HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD182000, "R&D Tax Reliefs: reformed reliefs: claims process: additional information form" (updated 25 August 2026), sections "Statutory framework", "What information is required" and "Failure to provide complete or proper responses". https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird182000 (accessed 11 October 2026).
Ireland Pre-filing notification at least 90 days before the claim, for first-time claimants and companies with no claim in the previous three accounting periods5Source 5Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766C, subsections (2) to (4), (9), (11), (12), (14), (16) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026).6Source 6Revenue Commissioners, Research and Development Corporation Tax Credit: Pre-filing Notification Form in respect of a claim to be made under section 766C TCA 1997, form and notes. https://www.revenue.ie/en/companies-and-charities/documents/rd-form-766c.pdf (accessed 11 October 2026). Expenditure details in the corporation tax return; no supporting R&D documents filed5Source 5Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766C, subsections (2) to (4), (9), (11), (12), (14), (16) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026).7Source 7Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 8, 8.1, 8.2, 8.4, 8.6.2 and Appendix 3. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-03.pdf (accessed 11 October 2026). No payment or offset without a valid claim5Source 5Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766C, subsections (2) to (4), (9), (11), (12), (14), (16) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026).
Canada No advance notice described; Form T661 is due 12 months after the return's filing due date8Source 8Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsections 37(11), (11.1) and (12). https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-37.html (accessed 11 October 2026). Form T661: project descriptions, evidence held, claim preparer details and certifications9Source 9Canada Revenue Agency, Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, T661 E (26), page 1, Part 2 (lines 200 to 282), Part 9 (lines 935 to 975 and billing arrangement codes), Part 10 (lines 165 to 175) and privacy notice. https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t661/t661-26e.pdf (accessed 11 October 2026). No deduction if prescribed information is missing; a late form means the expenditure is not SR&ED8Source 8Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsections 37(11), (11.1) and (12). https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-37.html (accessed 11 October 2026).
Singapore None for the R&D tax measures, which are self-assessed10Source 10Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 1.1, 2.2 and 11.1 (with footnote 21). https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf?sfvrsn=1f38a2e8_27 (accessed 11 October 2026). R&D Claim Form, filed with Form C or kept for Form C-S10Source 10Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 1.1, 2.2 and 11.1 (with footnote 21). https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf?sfvrsn=1f38a2e8_27 (accessed 11 October 2026).11Source 11Inland Revenue Authority of Singapore, Research and Development (R&D) Claim Form (YA 2019 and onwards), Part 1, item 1C, and Part 4 "Declaration". https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/rnd-claim-form-(ya-2019-n-after).pdf?sfvrsn=72929970_40 (accessed 11 October 2026). An EIS cash payout made without entitlement is recoverable as a debt12Source 12Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37R(1), (2), (24), (27), (30) and (34). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37R- (accessed 11 October 2026).

Notes

United States. For tax years beginning after 2025, Section G of Form 6765 is required unless an exception applies, for example for smaller claims on an original return.1Source 1Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), Purpose of Form, What's New, Section E, "Requirements To Complete Section G", "How To Complete Section G", "Statistical Sampling", "Column 49(f)" and "Research Credit Claims on Amended Returns". https://www.irs.gov/instructions/i6765 (accessed 11 October 2026). A taxpayer must keep records in sufficiently usable form and detail to substantiate that the expenditures claimed are eligible.13Source 13Treasury Department and Internal Revenue Service, 26 CFR 1.41-4, Qualified research for expenditures paid or incurred in taxable years ending on or after December 31, 2003, paragraph (d). https://www.ecfr.gov/current/title-26/section-1.41-4 (accessed 11 October 2026). The IRS states that the 45-day transition period for perfecting refund claims runs through 10 January 2027.2Source 2Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 4, 7 and 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).

United Kingdom. Other measures include a PAYE-related cap on SME claims and, for claims made on or after 1 April 2024, payment of R&D tax credits generally only to the claimant company.14Source 14HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), sections 1.2, 2.1 (Table 2), 2.2 (Table 3), 2.3 and 2.5. https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).15Source 15HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD81805, "R&D tax relief: conditions to be satisfied: restriction of nominations and assignments" (updated 25 August 2026). https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird81805 (accessed 11 October 2026). HMRC's published estimates put error and fraud in the R&D reliefs at 17.6 percent of the amount claimed in 2021 to 2022.14Source 14HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), sections 1.2, 2.1 (Table 2), 2.2 (Table 3), 2.3 and 2.5. https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).

Ireland. Revenue states that a company must be able to show its claim satisfies a "science test" and an "accounting test", with contemporaneous records available for inspection.7Source 7Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 8, 8.1, 8.2, 8.4, 8.6.2 and Appendix 3. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-03.pdf (accessed 11 October 2026). Revenue may examine a claim after the credit has been paid or offset.5Source 5Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766C, subsections (2) to (4), (9), (11), (12), (14), (16) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026).

Canada. Part 9 of Form T661 names each paid claim preparer, the billing arrangement and the total fee, with a $1,000 penalty for missing, incomplete or inaccurate information.9Source 9Canada Revenue Agency, Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, T661 E (26), page 1, Part 2 (lines 200 to 282), Part 9 (lines 935 to 975 and billing arrangement codes), Part 10 (lines 165 to 175) and privacy notice. https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t661/t661-26e.pdf (accessed 11 October 2026).16Source 16Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsections 162(5.1), (5.2) and (5.3). https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-162.html (accessed 11 October 2026). Budget 2025 announced administrative changes to the program from April 1, 2026, and targeted consultations that include reviewing Form T661.17Source 17Department of Finance Canada, Budget 2025, Chapter 1, section "Enhancing the Scientific Research and Experimental Development Tax Incentives". https://budget.canada.ca/2025/report-rapport/chap1-en.html (accessed 11 October 2026).

Singapore. IRAS offers an optional R&D Assurance Framework that gives upfront certainty for up to three Years of Assessment to companies that meet its thresholds.18Source 18Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 14.1 and 14.2. https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf?sfvrsn=1f38a2e8_27 (accessed 11 October 2026). Records must generally be kept for five years, or seven years where an EIS cash payout is elected.19Source 19Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 67(1)(a). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr67- (accessed 11 October 2026).12Source 12Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37R(1), (2), (24), (27), (30) and (34). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37R- (accessed 11 October 2026).

Sources

  1. Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), Purpose of Form, What's New, Section E, "Requirements To Complete Section G", "How To Complete Section G", "Statistical Sampling", "Column 49(f)" and "Research Credit Claims on Amended Returns". https://www.irs.gov/instructions/i6765 (accessed 11 October 2026).    Back
  2. Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 4, 7 and 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).     Back
  3. HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (last updated 31 October 2024), sections "Who needs to submit the form", "When to submit the form", "Working out your claim notification period" and "What information you'll need". https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).   Back
  4. HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD182000, "R&D Tax Reliefs: reformed reliefs: claims process: additional information form" (updated 25 August 2026), sections "Statutory framework", "What information is required" and "Failure to provide complete or proper responses". https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird182000 (accessed 11 October 2026).   Back
  5. Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766C, subsections (2) to (4), (9), (11), (12), (14), (16) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026).     Back
  6. Revenue Commissioners, Research and Development Corporation Tax Credit: Pre-filing Notification Form in respect of a claim to be made under section 766C TCA 1997, form and notes. https://www.revenue.ie/en/companies-and-charities/documents/rd-form-766c.pdf (accessed 11 October 2026).  Back
  7. Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 8, 8.1, 8.2, 8.4, 8.6.2 and Appendix 3. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-03.pdf (accessed 11 October 2026).   Back
  8. Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsections 37(11), (11.1) and (12). https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-37.html (accessed 11 October 2026).   Back
  9. Canada Revenue Agency, Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, T661 E (26), page 1, Part 2 (lines 200 to 282), Part 9 (lines 935 to 975 and billing arrangement codes), Part 10 (lines 165 to 175) and privacy notice. https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t661/t661-26e.pdf (accessed 11 October 2026).   Back
  10. Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 1.1, 2.2 and 11.1 (with footnote 21). https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf?sfvrsn=1f38a2e8_27 (accessed 11 October 2026).   Back
  11. Inland Revenue Authority of Singapore, Research and Development (R&D) Claim Form (YA 2019 and onwards), Part 1, item 1C, and Part 4 "Declaration". https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/rnd-claim-form-(ya-2019-n-after).pdf?sfvrsn=72929970_40 (accessed 11 October 2026).  Back
  12. Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37R(1), (2), (24), (27), (30) and (34). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37R- (accessed 11 October 2026).   Back
  13. Treasury Department and Internal Revenue Service, 26 CFR 1.41-4, Qualified research for expenditures paid or incurred in taxable years ending on or after December 31, 2003, paragraph (d). https://www.ecfr.gov/current/title-26/section-1.41-4 (accessed 11 October 2026).  Back
  14. HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), sections 1.2, 2.1 (Table 2), 2.2 (Table 3), 2.3 and 2.5. https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).   Back
  15. HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD81805, "R&D tax relief: conditions to be satisfied: restriction of nominations and assignments" (updated 25 August 2026). https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird81805 (accessed 11 October 2026).  Back
  16. Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsections 162(5.1), (5.2) and (5.3). https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-162.html (accessed 11 October 2026).  Back
  17. Department of Finance Canada, Budget 2025, Chapter 1, section "Enhancing the Scientific Research and Experimental Development Tax Incentives". https://budget.canada.ca/2025/report-rapport/chap1-en.html (accessed 11 October 2026).  Back
  18. Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 14.1 and 14.2. https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf?sfvrsn=1f38a2e8_27 (accessed 11 October 2026).  Back
  19. Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 67(1)(a). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr67- (accessed 11 October 2026).  Back