What tax authorities changed | Research Credit Integrity Alliance

Key points

The IRS has required specific information with research credit refund claims since January 2022, and has added Section G to Form 6765, optional for tax years beginning before 2026 and required, with exceptions, after that.12
HMRC requires a claim notification for some companies for accounting periods beginning on or after 1 April 2023, and an additional information form for R&D claims made on or after 8 August 2023.34
Revenue in Ireland requires a pre-filing notification at least 90 days before a first R&D tax credit claim, for accounting periods beginning on or after 1 January 2024.5
Canada has required claim preparer information, including the billing arrangement, on SR&ED claims filed on or after 1 January 2014.67
Singapore offers an R&D Assurance Framework.8

Scope of this article

This article records what tax authorities have changed in how research and development claims are made, with dates as each authority states them. It is factual. It does not assess whether any measure has worked, and it makes no recommendation for any country other than the United States. For who may prepare claims in each country, see Unregulated claim preparers.

United States: refund claim information and Form 6765 Section G

Information required with refund claims

The IRS states that, under existing Treasury regulations, a refund claim is valid only if it sets out sufficient facts to tell the IRS the basis of the claim.1 For a refund claim involving the research credit under Section 41, the IRS requires the taxpayer, at the time the claim is filed, to:

identify all the business components to which the claim relates for that year;
for each business component, identify all research activities performed;
name the individuals who performed each research activity;
identify the information each individual sought to discover; and
provide the total qualified employee wage, supply and contract research expenses for the claim year, which may be done using Form 6765.1

The IRS calls these the "five items of information" and refers to a Chief Counsel memorandum published on 15 October 2021.1 It gave a grace period until 10 January 2022 before requiring them with timely filed research credit refund claims.1 After the grace period it granted a one-year transition period, later extended twice through 10 January 2027, during which taxpayers have 45 days to perfect a deficient claim before the IRS makes a final determination.1

On 18 June 2024 the IRS waived the requirement to provide two of the five items with the claim: the names of the individuals who performed each research activity and the information each individual sought to discover. That information may still be requested if the claim is selected for examination.1 The IRS also states that a submission that only repeats the legal definitions and requirements of the Code or regulations will be treated as insufficient.1

Section G of Form 6765

The IRS instructions for Form 6765 (revised December 2025) describe a Section G, Business Component Information.2 For tax years beginning before 2026, Section G is optional for all filers. For tax years beginning after 2025, it is required, unless the taxpayer is a qualified small business electing the payroll tax credit, or its total qualified research expenses are $1.5 million or less, its average annual gross receipts for the prior three years are $50 million or less, and it is reporting the credit on an original return.2

Where Section G is required, the taxpayer reports information by business component for at least 80 percent of total qualified research expenses, up to a maximum of 50 business components, listed in descending order of expense.2 The instructions ask that each business component's name or identifier be consistent with how the taxpayer maintains the books and records that substantiate the research activities and expenses.2 Column 49(f) currently applies to amended returns that claim a research credit not reported on the original return, or an increased one.2

Form 6765 does not ask who prepared the claim or how they were paid. The preparer of a return or refund claim is identified by the preparer's identifying number, which the Internal Revenue Code requires on any return or claim prepared by a tax return preparer.9

United Kingdom: claim notification and the additional information form

Claim notification

HMRC states that, for accounting periods beginning on or after 1 April 2023, a company must submit a claim notification form if it is claiming R&D tax relief or expenditure credit for the first time, or if its last claim was made more than three years before the last date of its claim notification period.3 The notification period starts on the first day of the period of account and ends six months after its end. If a required notification is not made in time, the claim is invalid.3 The form may be completed by a representative of the company or by an agent acting for it.3

Additional information form

HMRC's manual explains that paragraph 83EA of Schedule 18 to the Finance Act 1998, inserted by the Finance (No. 2) Act 2023, gives HMRC power to specify information required in support of an R&D claim, and that regulations made under it require the information for claims made on or after 8 August 2023.4 If the information is not provided, the claim is invalid.4

The additional information form must be submitted before, or on the same day as, the Company Tax Return. If it is not submitted, any R&D claim will not be accepted.10 It asks for project-level details: the field of science or technology, the knowledge the project sought to advance, the uncertainties it faced and how it sought to overcome them.4 HMRC states that answers must address the question asked and that referring to documents outside the form, such as "see R&D report", is not acceptable.4

The form also asks who is involved. It requires contact details for the main senior internal R&D contact responsible for the claim, and for all agents involved in the claim, including any agent who gave advice, analyzed costs, helped prepare technical assessments, or completed the forms or the return.10 An agent completing the form must use an agent services account.10

Reporting and registration

In September 2025 HMRC published a route for agents and accountancy professionals to report another agent they suspect of poor R&D tax relief service standards, such as giving misleading information or dishonest behavior.11 Separately, HMRC is introducing in stages a requirement for anyone paid to interact with HMRC about someone else's tax affairs to register for an agent services account, with registration windows that include 18 August 2026, 18 November 2026 and 31 December 2026 for particular groups.12

Ireland: pre-filing notification

Revenue states that, for accounting periods beginning on or after 1 January 2024, companies claiming the R&D Corporation Tax Credit for the first time, or that have not claimed it in the previous three years, must notify Revenue before making the claim.5 The pre-filing notification form must be filed at least 90 days before the claim is made, through MyEnquiries.5

The form is a legislative requirement under section 766C(17) of the Taxes Consolidation Act 1997.13 It asks for the number of employees carrying on R&D activities, the number of R&D projects, details of expenditure met by grant or other assistance, and a description of the qualifying R&D activities. It is signed on behalf of the company.13 Revenue's manual gives an example: a company that intends to file its first claim on 31 March 2027 for the year ended 31 December 2026 should file the notification on or before 31 December 2026.14

The form does not ask for details of any adviser.13

Canada: claim preparer information on Form T661

The CRA revised Form T661 in 2013 to add a Part 9 for claim preparer information.6 The information includes the name and business number of each claim preparer, the billing arrangement, the billing rate, any other billing arrangement and the total fee.6 The CRA's account of the 2013 federal budget measure says the form would capture details of billing arrangements, including whether contingency fees were used and the amount of fees payable, and that where no preparer was involved the taxpayer would certify that.7

The CRA states that the measure applies to claims filed on or after the later of 1 January 2014 and Royal Assent, that it received Royal Assent on 12 December 2013, and that the new rules became effective on 1 January 2014.7 Under the Income Tax Act, a false statement or omission in the claim preparer information makes the claimant and any claim preparer jointly and severally, or solidarily, liable for a $1,000 penalty.15 A claim preparer is not liable if it exercised the degree of care, diligence and skill that a reasonably prudent person would have exercised in comparable circumstances.15

Singapore: claim form, documentation and the Assurance Framework

IRAS requires a company to make its R&D claim in its corporate income tax return and complete the R&D Claim Form. Companies filing Form C file the claim form with the return. Companies filing Form C-S or Form C-S (Lite) keep it and submit it on request.8 IRAS states that a company must maintain proper documentation of its R&D projects from the start of the project, rather than as an after-event, so that it can substantiate its claims.8

IRAS also operates an R&D Assurance Framework, which gives upfront certainty on R&D claims for up to three Years of Assessment. To apply, a company needs good internal evaluation processes and documentation, at least five in-house R&D projects in Singapore, and at least $500,000 of qualifying R&D expenditure in the year of application. Applications are made at least nine months before the filing deadline for that year.8

The IRAS guidance consulted does not state when the Assurance Framework was introduced.

What the measures have in common

The measures differ in form. Some ask for more detail about the research itself: the IRS refund claim information and Section G, the UK additional information form and Ireland's pre-filing notification.12413 Some ask who helped prepare the claim: the UK form's list of agents and Canada's Part 9.106 Of the measures described here, only Canada's asks how the preparer was paid.67

Sources

Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 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
Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), What's New, and sections "Section G, Business Component Information", "Requirements To Complete Section G", "How To Complete Section G" and "Column 49(f)". https://www.irs.gov/instructions/i6765 (accessed 11 October 2026). Back
HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (updated 31 October 2024). https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026). Back
HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD182000, R&D Tax Reliefs: reformed reliefs: claims process: additional information form (updated 19 March 2025), 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
Revenue Commissioners, Research and Development (R&D) Corporation Tax credit: Pre-filing notification requirement (published 18 July 2025). https://www.revenue.ie/en/companies-and-charities/reliefs-and-exemptions/research-and-development-rd-tax-credit/pre-filing.aspx (accessed 11 October 2026). Back
Canada Revenue Agency, SR&ED T661 Claim Form, 2013 Revision, Claim preparer information (31 October 2013). https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/whats-new-program/t661-claim-form-2013-revision-claim-preparer-information.html (accessed 11 October 2026). Back
Canada Revenue Agency, Budget 2013, Scientific Research and Experimental Development (SR&ED) Tax Incentive Program, section on claim preparer information and penalty. https://www.canada.ca/en/revenue-agency/programs/about-canada-revenue-agency-cra/federal-government-budgets/budget-2013/budget-2013-scientific-research-experimental-development-tax-incentive-program.html (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Research and Development (R&D) Tax Measures, sections "How to Claim R&D Tax Deductions", "Documentation" and "R&D Assurance Framework". https://www.iras.gov.sg/taxes/corporate-income-tax/income-deductions-for-companies/business-expenses/research-development-(r-d)-tax-measures (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6109, Identifying numbers, subsection (a)(4), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap61-subchapB-sec6109.htm (accessed 11 October 2026). Back
HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief, sections "When to submit", "Who can submit" and "Contact details" (updated 26 September 2025). https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026). Back
HM Revenue and Customs, Reporting poor R&D tax relief service standards (first published 26 September 2025). https://www.gov.uk/guidance/reporting-poor-rd-tax-relief-service-standards (accessed 11 October 2026). Back
HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC, sections "Who needs to register" and "When to register" (updated 3 September 2026). https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026). Back
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
Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), section 8.6.1 and Example 31. 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
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

This article discusses fee practices in general terms. It is not a statement about any particular adviser.