Ireland: Fee rules | Research Credit Integrity Alliance

This page records what Irish statute and Revenue guidance say about fees for tax work, and in particular for preparing claims for the research and development (R&D) corporation tax credit. It covers rules aimed at fees themselves, rules on how money from a claim flows, and the general rules that apply to anyone who helps a company prepare a return, whatever the basis of their fee. Professional body codes are covered separately on the professional body rules page.

No specific rule on contingent fees in the R&D provisions

The R&D corporation tax credit is governed by section 766C of the Taxes Consolidation Act 1997 (TCA 1997), with the definitions in section 766 continuing to apply.1 Revenue's commentary on section 766C covers the rate of the credit, the instalments, the details a claim must contain, the pre-filing notification, the charge on unauthorized claims and the payment timetable.1 It contains no provision on how a person who prepares a claim may be paid.1

Revenue's main guidance on the credit, Tax and Duty Manual Part 29-02-03, also contains no rule on the basis of a claim preparer's fee.2 Its references to "fees" concern items of expenditure, such as recruitment fees counted among a company's indirect overheads, not the preparer's charges.2

Revenue's guidelines for agents and advisers, Tax and Duty Manual Part 37-00-04b, set out how agents register and act for clients. They do not set a rule on the basis on which an agent may charge.3

Rules on how payments from a claim flow

Although no source reviewed regulates the fee basis, two rules affect how money from an R&D claim moves.

The credit goes to the company. Under section 766C(7), the company specifies, for each of the three instalments, whether the amount is to be treated as an overpayment of tax (and offset against its liabilities) or paid to the company by Revenue.1

Agents may not receive business tax refunds. Revenue's guidelines state that agents and advisers are not permitted to directly receive refunds in respect of their clients' business taxes.3 Revenue previously allowed agents acting for PAYE (employee) taxpayers to receive refunds and deduct their fee where a Form PAYE A2 mandate was in place. The guidelines state that the A2 form could no longer be used for new links from 1 January 2025, and that agents may not receive refunds into their own bank account for PAYE clients linked after that date.3 That former PAYE facility did not apply to business taxes such as corporation tax.3

General rules that apply whatever the fee basis

Several provisions of the TCA 1997 apply to anyone who helps prepare a return or claim. They do not depend on how the person is paid.

Provision	What it says	Applies to
Section 1055	A penalty of €4,000 on any person who deliberately assists in or induces the making or delivery of an incorrect income tax or corporation tax return, account, statement or declaration.4	Any person
Section 1078(2)(b)	It is an offence to knowingly aid, abet, assist, incite or induce another person to make or deliver, knowingly or wilfully, an incorrect return, statement or accounts in connection with any tax.4	Any person
Section 1079	Auditors, and any person who for reward assists or advises a company in preparing documents likely to be used for tax purposes, must act if they become aware of certain material tax offences by the company, and may have to cease acting.4	"Relevant persons"
Section 1077F(16)	Accounts submitted on behalf of a person are deemed to have been submitted by that person unless the person proves they were submitted without their consent or knowledge.4	The taxpayer

Revenue's guidelines for agents state that, on a conviction under section 1078, the penalty can be €5,000 on summary conviction and up to €126,970 on indictment, or imprisonment, or both.3 Revenue's Code of Practice for Revenue Compliance Interventions states that, in exceptional cases where a tax practitioner actively engages with a client to assist in tax evasion or avoidance, Revenue will seek a penalty under section 1055 or press for prosecution under section 1078(2).5

Who bears an incorrect claim

The company that claims the credit bears the consequences of an incorrect claim. Where a claim is found not to be authorized by section 766C, the company may be charged to tax under Case IV of Schedule D on four times the unauthorized amount.1 Revenue's Code of Practice states that a taxpayer cannot devolve the responsibility of making a correct return to an agent.5 The penalties page sets out the charges in detail.

Disclosure of fees to Revenue

No source reviewed requires a company or its adviser to tell Revenue how the adviser was paid. The details a company must give with a claim under section 766C(9)(b), and in the pre-filing notification under section 766C(17), concern the company, its R&D activities, its employees and its expenditure.16 Neither list includes the adviser's fee or how it was calculated.16

Summary

Question	Position in the sources reviewed
Statutory rule on contingent fees for R&D claims	None found in section 766C or Revenue's R&D guidance12
Can an agent receive the credit or a business tax refund directly?	No: the credit is paid or offset to the company, and agents may not receive clients' business tax refunds13
Must the fee basis be disclosed to Revenue?	Not in the claim details or pre-filing notification16
Penalties for assisting an incorrect return	Yes, under sections 1055 and 1078, whatever the fee basis4

Sources

Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766C, subsections (6), (7), (9), (10) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.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), whole document, including section 4.1. 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
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 3, 7, 13 and 14. 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
Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 47, sections 1055, 1077F(16), 1078(2) and 1079. https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part47.pdf (accessed 11 October 2026). Back
Revenue Commissioners, Code of Practice for Revenue Compliance Interventions (effective 1 May 2022), sections 1.5.3 and 4.6.2. https://www.revenue.ie/en/tax-professionals/documents/code-of-practice-revenue-compliance-interventions.pdf (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