United Kingdom: Overview

This page summarizes how advisers on United Kingdom research and development (R&D) tax relief claims are paid, what the rules say about their fees and conduct, and where the official record is silent. It describes the rules as they stand. It makes no recommendation for the United Kingdom.

The relief and the authority

HM Revenue and Customs (HMRC) administers the Corporation Tax R&D reliefs.1 For accounting periods beginning on or after 1 April 2024, the merged R&D expenditure credit (RDEC) scheme and enhanced R&D intensive support (ERIS) replace the earlier RDEC and small and medium-sized enterprise (SME) schemes. The merged RDEC rate is 20 percent. ERIS is for loss-making, R&D intensive SMEs.2

How advisers are paid

HMRC states that more than 90 percent of R&D claimants have an authorized agent acting for them, and that in its second random enquiry program around half of all companies used a specialist R&D agent.3

The official sources describe several ways an adviser may be paid. The Chartered Institute of Taxation (CIOT) and the Association of Taxation Technicians (ATT) list time and expenses, fixed fees, contingent (including success) fees, and fees covered by insurance as possible arrangements for their members.4 HMRC's standard for agents says that terms of engagement should be as clear and simple as possible, in particular about how the agent is to be paid and what deductions the agent will make from any repayment it handles.5

Until 2024 an agent could receive a client's R&D tax credit through a nomination. For claims made on or after 1 April 2024, HMRC will generally pay R&D tax credits only to the claimant company, subject to exceptions for connected parties and exceptional circumstances.6 HMRC said the change would help reduce non-compliance "by reducing the financial incentive for agents to overstate claims", and that more than 90 percent of claims that are fraudulent or show some markers of fraud use nominee bank accounts.3

HMRC's published R&D material reviewed for this page does not report how many claims are prepared on a contingent fee basis, or the level of fees charged.

What the rules say

Legislation. No provision of UK tax legislation that caps or prohibits contingent fees for preparing R&D claims was identified for this page. Statute does govern who receives the money: the restriction on nominations is in section 1142D of the Corporation Tax Act 2009.6 See Fee rules.

HMRC's standard for agents. The standard sets out HMRC's expectations of everyone acting as a tax agent, including agents who help clients claim reliefs. It expects agents to avoid including figures in claims which are unsubstantiated or speculative.5 See HMRC Standard for Agents.

Registration. Anyone paid to interact with HMRC about someone else's tax affairs, including by sending claims, must now register for an agent services account, with registration windows phased through 2026.7 See Adviser registration.

Professional bodies. Professional Conduct in Relation to Taxation (PCRT) is produced jointly by seven professional bodies and binds their members.8 The CIOT and ATT rules say contingent fees can carry increased risks and that members using them should ensure their conduct meets, and is seen to meet, the principles of integrity and objectivity.4 The ICAEW Code of Ethics treats contingent fees as a possible self-interest threat to objectivity and prohibits them for audit engagements.9 See Professional body rules.

What a claim must include

Some companies must notify HMRC in advance. For accounting periods beginning on or after 1 April 2023, a company claiming for the first time, or whose last claim was more than three years before the end of its claim notification period, must notify HMRC within a period ending six months after the end of the period of account. Otherwise the claim is invalid.10 See Claim notification.

For claims made on or after 8 August 2023, the company must provide additional information on or before the date of the claim, or the claim is invalid.11 Both the claim notification and the additional information form ask for the contact details of all agents involved in the claim.1012 See Additional Information Form and Preparer identification.

Review, penalties and appeals

HMRC risk assesses each claim, using the additional information form, and opened compliance checks on 17 percent of claims in 2023 to 2024.3 A company that sends an inaccurate claim may be charged a penalty of up to 30 percent of the potential lost revenue for a careless inaccuracy, and up to 100 percent where the inaccuracy is deliberate and concealed.13 Since 1 April 2026, HMRC may charge a tax adviser a penalty for sanctionable conduct, meaning conduct intended to bring about a loss of tax revenue.14 A company that disagrees with a decision on its claim can appeal, ask for a statutory review and then go to the First-tier Tribunal (Tax).15 See Reviews and audits, Penalties and Disputes and appeals.

Open questions

The official record leaves several points open:

Fee data. HMRC's published breakdown of claims made with a specialist R&D agent is by size of claim. It does not show how the agent was paid.3
Fee disclosure to HMRC. The fields HMRC lists for the additional information form cover each agent's name, business, telephone number and email address. They do not include the basis or amount of the agent's fee.11
Competence. The registration conditions for tax advisers concern anti-money laundering supervision, tax compliance, convictions, sanctions, insolvency and disqualification. They do not include a qualification requirement.16
Effect of recent measures. The National Audit Office reported in 2024 that the impact of HMRC's actions on R&D error and fraud would not become clear until 2024 to 2025 and beyond.1

Every source used for the United Kingdom is listed on Sources.

Sources

National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, paragraphs 2.2 and 2.21. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). Back
HM Revenue and Customs, Research and Development (R&D) Tax Relief: the merged scheme and enhanced R&D intensive support (last updated 8 January 2026), sections "The merged R&D expenditure credit scheme and enhanced R&D intensive support scheme", "The merged R&D expenditure credit" and "Enhanced R&D intensive support". https://www.gov.uk/guidance/research-and-development-rd-tax-relief-the-merged-scheme-and-enhanced-rd-intensive-support (accessed 11 October 2026). Back
HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), sections 2.1, 2.4 and 2.5, and Annex B, Theme 5 and Table B.4. 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
Chartered Institute of Taxation and Association of Taxation Technicians, Professional Rules and Practice Guidelines (effective 9 November 2018, updated 1 January 2021), paragraphs 8.1.2 and 8.2.1 to 8.2.5. https://www.att.org.uk/sites/default/files/PRPG%20%28Update%201.1.2021%29%20-%20Final.pdf (accessed 11 October 2026). Back
HM Revenue and Customs, The HMRC standard for agents (updated 9 February 2026), sections 1.1, 4.2 and 4.3.3. https://www.gov.uk/government/publications/hmrc-the-standard-for-agents/the-hmrc-standard-for-agents (accessed 11 October 2026). Back
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
HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Who needs to register" and "When to 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
AAT, ACCA, ATT, CIOT, ICAEW, ICAS and STEP, Professional Conduct in Relation to Taxation (effective 1 January 2026, published 1 October 2025), Foreword and paragraphs 1.2 and 1.11. https://www.icaew.com/-/media/corporate/files/technical/tax/pcrt/pcrt-effective-1-january-2026.ashx (accessed 11 October 2026). Back
ICAEW, ICAEW Code of Ethics 2026 (applies from 1 July 2026), section 330, "Contingent Fees", and paragraph R410.9. https://www.icaew.com/-/media/corporate/files/technical/ethics/code-of-ethics/icaew-code-of-ethics-2026-revisions-highlighted.ashx (accessed 11 October 2026). Back
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" 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
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" and "What information is required". https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird182000 (accessed 11 October 2026). Back
HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), sections "When to submit", "Who can submit" and "Contact details". 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, Penalties for inaccuracies in returns and documents: CC/FS7a (updated 21 July 2026), section "How we work out the amount of a penalty", stage 4. https://www.gov.uk/government/publications/compliance-checks-penalties-for-inaccuracies-in-returns-or-documents-ccfs7a/compliance-checks-for-penalties-of-inaccuracies-in-returns-or-documents-ccfs7a-factsheet (accessed 11 October 2026). Back
HM Revenue and Customs, Compliance Handbook, CH176100, "Sanctionable conduct by tax advisers: Overview", and CH176140, "Commencement date" (manual updated 7 October 2026). https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch176100 (accessed 11 October 2026). Back
GOV.UK, Disagree with a tax decision or penalty, sections "Disagree with a tax decision" and "Get a review". https://www.gov.uk/tax-appeals/print (accessed 11 October 2026). Back
HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), section "The registration conditions". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026). Back

At a glance

The relief and the authority

How advisers are paid

What the rules say

What a claim must include

Review, penalties and appeals

Open questions

Sources

Register your interest

At a glance

The relief and the authority

How advisers are paid

What the rules say

What a claim must include

Review, penalties and appeals

Open questions

Sources

More on United Kingdom

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