Ireland and Singapore claim controls

1Summary

Ireland and Singapore both support business research and development through the tax system, and both rely on the claimant company to assess whether its activities qualify. Neither requires advance approval of every claim. Each has instead built controls around the claim.

Ireland's controls are mainly procedural and statutory. A company claiming the research and development (R&D) corporation tax credit for the first time, or after three accounting periods without a claim, must notify Revenue at least 90 days before it claims.12 The claim itself is made in the corporation tax return with specified expenditure details, and is paid only once a valid claim is made.13 Revenue may consult independent experts on the science, after telling the company who they are and what will be disclosed.14

Singapore's controls center on information and review. A company filing Form C must submit an R&D Claim Form with its return, describing each project's objective, technical risk, novelty and experimental study.56 The Inland Revenue Authority of Singapore (IRAS) reviews claims with advice from a Technical Advisory Panel, and offers larger R&D performers an assurance framework that gives upfront certainty.67

This paper sets out these controls and compares them. It describes the facts only and makes no recommendation for either country. It finds that in both countries the company bears the consequences of an incorrect claim, and that neither country's R&D claim documents ask who prepared a claim or how an adviser was paid.

2Why compare these two systems

Both systems are self-assessed. Revenue's guidance states that a company may claim the Irish credit by completing Form CT1 where it is satisfied that it can comply with the legislation and has maintained the necessary records.3 IRAS's e-Tax Guide states that a taxpayer "need not apply to any government agency" for the R&D tax measures, and "must self-assess if his R&D activities are qualifying R&D activities for tax purpose".6

Both systems also turn on scientific judgment. Ireland's definition of R&D activities requires, among other things, activities that seek scientific or technological advancement and involve the resolution of scientific or technological uncertainty.23 Singapore's definition in section 2 of its Income Tax Act 1947, as explained by IRAS, requires an objective to acquire new knowledge or create or improve products or processes, novelty or technical risk, and a systematic, investigative and experimental study.56

Where eligibility depends on judgment and the claimant assesses it, the controls placed around the claim determine what the tax authority learns, when it learns it, and who answers for the result. The two countries answer those questions differently.

3Ireland

3.1The credit

For accounting periods beginning on or after 1 January 2024, the R&D corporation tax credit under section 766C of the Taxes Consolidation Act 1997 (TCA 1997) is given at 30 percent of allowable expenditure.3 Revenue's manual states that for accounting periods with a specified return date on or after 23 September 2027 the rate is 35 percent, which in general applies to accounting periods ending on or after 31 December 2026.3

A claim must be made within 12 months of the end of the accounting period in which the expenditure was incurred.13 The credit is paid or offset in three instalments within 48 months of a valid claim.1

3.2Before the claim: pre-filing notification

Section 766C(17) requires a company that has not claimed the credit in any of its previous three accounting periods to notify Revenue in writing, on a prescribed form, at least 90 days before the claim is made.1 The requirement applies for accounting periods beginning on or after 1 January 2024, and does not apply where the company has claimed in any of the three immediately preceding accounting periods.13

The statute lists particulars the form must include: the company's name, address and corporation tax number; a description of its R&D activities; the number of employees carrying on R&D activities; and details of expenditure met directly or indirectly by grant or other assistance.1 The prescribed form asks for those items, the number of R&D projects (an estimate if not finalized), and a brief synopsis giving an understanding of the R&D undertaken by the company as a whole, with examples of projects.2 Revenue may require additional information, explanations and particulars.1

The form states that it "is not a claim for the R&D corporation tax credit".2 It is filed through MyEnquiries, and the company later ticks a box on the R&D panel of Form CT1 to show it was submitted.23 Revenue's manual gives an example: a company that intends to claim on 31 March 2027 for the period ended 31 December 2026 should file its notification on or before 31 December 2026.3

The Revenue sources reviewed for this paper do not state the purpose of the notification. Its effect is that Revenue learns of a new claimant, and of its activities, before the claim arrives.

3.3The claim in Form CT1

The claim is made by completing the relevant sections of Form CT1 through the Revenue Online Service.3 Section 766C(9) and Revenue's manual require the company to give:

the amounts of the first, second and third instalments claimed, and whether each is to be treated as an overpayment of tax or paid to the company;3
its R&D expenditure on plant or machinery, the emoluments of employees carrying on R&D activities, and its remaining qualifying expenditure, net of grant funding;13
any non-refundable credits carried forward from earlier claims.13

No supporting R&D documentation is submitted with the return, but it may be requested later to verify that the claim is valid.3 No amount is paid or offset unless a valid claim has been made, meaning one that provides all the information Revenue may reasonably require to determine whether, and to what extent, the credit is due.1 Revenue states that the valid claim concept is not new and was written into the legislation so that the payment timelines operate as intended.3 Revenue may examine a claim and make or amend an assessment after the credit has been paid or offset.1

3.4Records: the science test and the accounting test

Revenue's manual states that a company must be able to show that its claim satisfies two tests: that the activity is qualifying R&D (the "Science Test") and that the costs have been properly tracked and accounted for (the "Accounting Test").3 Contemporaneous records, in hard copy or electronic form, must be available for inspection by Revenue officials.3 Revenue publishes a suggested file layout, formulated from the experience of its compliance officers and independent experts.3

Revenue has also limited its own review in one category. To reduce the burden of engaging experts, it will not, as a rule, challenge the science test for a project that has an approved R&D grant from Enterprise Ireland, IDA, Horizon 2020 or Horizon Europe, where the project is in a prescribed field, the company is a micro or small enterprise, and the total credit claimed for the period is 50,000 euro or less.3

3.5Expert consultation

Section 766(7)(a) allows Revenue to consult any person who in its opinion may help it decide whether expenditure was incurred in carrying on R&D activities, and Revenue's manual confirms this applies to claims under section 766C.13 Before disclosing information, Revenue must tell the company who it intends to consult and what it intends to disclose. If the company shows, to Revenue's satisfaction or on appeal, that disclosure to that person could prejudice its business, the disclosure is not made.1

Revenue's procedure for appointing experts is published in Tax and Duty Manual Part 29-02-05.4

Feature	Revenue's procedure
Recruitment	Applications invited through the public procurement website for a panel of experts.4
Qualification	A relevant PhD or experiential equivalent.4
Payment	1,000 euro per day plus reasonable expenses, with an engagement typically taking three days.4
When used	At the outset of a review, or where Revenue and the company reach an impasse on the science test; experts should be engaged only where there is doubt that the science test is met, not to explain the science.4
Company's objections	Conflict of interest, unsuitable expertise, or prejudice from disclosure, with 30 days to respond in Revenue's template letter.4
Expert's role	"not to support the opinion of the Revenue officer" but to give an independent opinion on whether the activities are qualifying R&D.4

The expert reports to Revenue, and may be required to give evidence before the Tax Appeals Commission or a court where the company disputes the opinion.3 A company may appeal to the Tax Appeals Commission against the use of a particular expert.3

3.6When a claim is not authorized

If a claim is subsequently found not to be authorized by section 766C, the company may be charged to tax under Case IV of Schedule D on an amount equal to four times the unauthorized amount.1 No loss, deficit, expense or allowance may shelter that charge, and it carries interest under section 1080 from the date the credit was paid or offset.1 For the penalties for deliberately or carelessly making an incorrect return, an unpaid claim is treated as an amount of tax refundable, so that penalties can apply to amounts offset, paid and unpaid.13 Revenue's manual states that where an R&D intervention results in a settlement, penalties apply in line with the legislation and the Code of Practice for Revenue Compliance Interventions, and that publication may also apply.3

3.7Who acts for the company

Revenue records who acts for a company through the Tax Advisor Identification Number (TAIN). An agent or adviser must have a TAIN before representing any Revenue customer, and the TAIN with a client link is how a taxpayer authorizes an agent.8 Revenue states that it "does not operate any system for approving tax agents or advisors", and that neither a TAIN nor a tax clearance certificate is an endorsement of an agent's conduct, experience or abilities.8 Agents and advisers are not permitted to receive refunds of their clients' business taxes directly.8

The pre-filing notification is signed on behalf of the company and has no field for an agent or preparer.2 The statutory details required with the claim do not include who prepared it or how that person was paid.1 Whether Form CT1 itself records a preparer was not confirmed for this paper.

4Singapore

4.1The deductions

Singapore gives R&D support mainly through enhanced deductions rather than a credit. IRAS describes a 100 percent deduction under section 14C of the Income Tax Act 1947 and an additional deduction under section 14D, which was 150 percent on qualifying staff costs and consumables for R&D in Singapore for Years of Assessment (YAs) 2019 to 2025.56 Under the Enterprise Innovation Scheme (EIS), announced in Budget 2023, IRAS states that an additional 300 percent deduction is granted on the first 400,000 dollars of qualifying R&D expenditure on staff costs and consumables for R&D undertaken in Singapore, for YAs 2024 to 2028.5 Eligible businesses may instead convert up to 100,000 dollars of total qualifying expenditure under the EIS each YA into cash at a rate of 20 percent.59

4.2No general pre-approval or pre-filing notice

The e-Tax Guide states that the taxpayer need not apply to any government agency for the R&D tax measures and must self-assess.6 No general requirement to notify IRAS before claiming was identified for this paper. The e-Tax Guide records that a previous "Pre-claim Scheme" was replaced in 2022 by the R&D Assurance Framework described below.6

4.3The R&D Claim Form

A company must make the R&D claim in its income tax return for the relevant YA and complete the R&D Claim Form.5 A company filing Form C files the claim form with its return. A company filing the simplified Form C-S or Form C-S (Lite) retains the completed form and submits it when IRAS asks.567 The filing deadline for the return is 30 November of the relevant YA.5

The claim form has six parts.7

Part	Content
1 and 2	Instructions, and a checklist: the project is in a field of science or technology, is not done as an R&D service provider for customers, is not on the exclusion list, and meets the three requirements.7
3	Company details and an overview of section 14C and 14D claims by project, reconciled to Form C.7
4	A declaration that the information is "true and complete", signed by an authorized person, with the statement "I am aware that penalties may be imposed for making incorrect or false declarations".7
5	For each project: dates, whether it continues a previously claimed project, in-house, outsourced or cost sharing, place of work, grants, and a separate write-up of the objective, technical risk, novelty and the systematic, investigative and experimental study, including "the qualification of the person(s) carrying out the study".7
5N and 5O	A checklist of supporting documents retained (not submitted), and a contact person for technical clarification.7
6	Expenditure and deduction calculations for each project.7

The form's list of supporting documents includes "Professional advice on why the R&D issue cannot be readily resolved".7 The e-Tax Guide also notes that where knowledge "is readily procured from experts in the relevant field of science or technology (e.g. consultants, academics)", the outcome is likely to be known or readily deducible, so a systematic study is not required.6

The form does not ask who prepared it or how any adviser was paid. Its declaration is made by an authorized person of the company.7

4.4Documentation

IRAS states that a company does not need to file supporting documents with its return, but must prepare and retain proper documentation from the start of the R&D project and present it on request.5 The e-Tax Guide encourages contemporaneous documentation "rather than as an after-event", which it says is especially important for showing that current knowledge was not available when the project began.6 IRAS states that smaller businesses may not formally document every step, and that it is prepared to accept other documentation such as working papers, email discussion and test results.56

4.5Review and the Technical Advisory Panel

IRAS first evaluates a claim on the information in the claim form and requests more where it is insufficient.6 Where appropriate, it may consult IPOS International Pte Ltd, a wholly owned subsidiary of the Intellectual Property Office of Singapore.56

IRAS has set up a Technical Advisory Panel to advise it and enhance its ability to review R&D claims. Panel members have given undertakings to keep taxpayers' information confidential.6 Cases are referred to the Panel where appropriate, including where the taxpayer specifically asks, or where IRAS rejects the claim after two rounds of review and the taxpayer wishes to pursue it.56 The Panel generally advises on the documents, may seek clarifications, and may ask to meet the company; IRAS states that such a meeting "is not an arbitration session".5 "With the technical advice from the Panel, IRAS makes the final decision".6 A taxpayer who disagrees can object to the assessment through the normal objection and appeal process.6

4.6The R&D Assurance Framework

The R&D Assurance Framework gives "upfront certainty" on R&D claims for up to three YAs, subject to IRAS's requirements.56 To apply, a company needs a good internal evaluation process and supporting documentation, at least five R&D projects undertaken in-house in Singapore in the YA of application, and qualifying R&D expenditure of at least 500,000 dollars for those projects.6 The application and a complete list of projects must be submitted at least nine months before the filing deadline.6 IRAS selects up to five projects or 20 percent of the total, whichever is higher, for detailed review, and continues to select sample projects for review in the second and third years.5 Companies must maintain detailed documentation whatever the outcome of their application.5

4.7Controls on the EIS cash payout

The EIS cash payout has controls of its own. An application for a cash payout on qualifying R&D must be accompanied by the R&D Claim Form.9 The election to convert expenditure into cash is irrevocable, and records must be kept for seven years.9 IRAS states that the payout can be paid only to the eligible person that incurred the expenditure, not to a third party.9 Under section 37S of the Income Tax Act 1947, giving IRAS information that is false in any material particular, or omitting a material particular, is an offence.9 Approval does not prevent a later audit, and IRAS will recover any payout incorrectly disbursed.9

4.8Penalties

IRAS states that a company that makes errors in its return may face, where there is no intention to evade, a penalty of up to 200 percent of the tax undercharged, a fine of up to 5,000 dollars and imprisonment of up to three years; and where there is an intention to evade, a penalty of up to 400 percent, a fine of up to 50,000 dollars and imprisonment of up to five years.10 Among possible indicators of negligence, IRAS lists that the taxpayer "has received prior information from IRAS or advice from its tax agents informing it of the correct tax treatment".10 Penalties may be reduced under IRAS's Voluntary Disclosure Programme.10

4.9What IRAS has published about outcomes

IRAS states that in 2018 about 520 companies claimed enhanced R&D benefits, that small and medium enterprises made up 85 percent of R&D claims, and that, based on the claims processed, 83 percent of SME claims were granted full R&D benefits, with another 6 percent adjusted by IRAS on the approved expenditure.5 No later figures, and no figures by how claims were prepared, were identified for this paper.

5The two systems compared

Control	Ireland	Singapore
Basis of claim	Self-assessed credit in Form CT13	Self-assessed deduction in the return6
Advance notice	Pre-filing notification at least 90 days before the claim for new or returning claimants1	None identified; optional assurance framework for larger performers56
Project information with the claim	Expenditure totals and instalments; no documentation filed3	Project-by-project write-up with Form C; retained for Form C-S57
Records	Contemporaneous records for the science and accounting tests3	Contemporaneous documentation encouraged; other records accepted from smaller businesses56
Outside technical expertise	Independent experts, with notice to the company and rights to object14	Technical Advisory Panel; IPOS International56
Consequence of an unauthorized claim	Case IV charge on four times the unauthorized amount, with interest; penalties13	Penalties up to 200 or 400 percent of tax undercharged; recovery of payouts910
Who signs	The company2	An authorized person of the company7
Preparer named or fee disclosed	Not in the statutory claim details or the notification12	Not on the R&D Claim Form7

The controls differ in timing. Ireland's notification gives Revenue information about new claimants before a claim is made. Singapore's claim form gives IRAS detailed project information at the time of the claim, for Form C filers, and its assurance framework offers advance certainty to larger performers who choose it.

The controls differ in how outside expertise enters. In Ireland, experts are engaged case by case on Revenue's behalf, and the company has statutory and procedural rights to know who they are and to object.14 In Singapore, a standing panel advises IRAS, and a company can ask for its case to be referred.56

The controls are alike in where responsibility sits. In both countries the company makes the declaration and bears the financial consequences of an incorrect claim.12710

6What the controls do not address

The controls described in this paper concern the company, its projects and its expenditure. None of the R&D claim documents reviewed in either country asks who prepared the claim or how that person was paid.127 Ireland records a company's agent through the TAIN system for tax purposes generally, but states that it does not approve agents.8

No rule specific to R&D claims on how an adviser may be paid was identified in either country's R&D legislation or guidance reviewed for this paper. Two rules touch the flow of money from a claim. In Ireland, agents may not receive clients' business tax refunds directly.8 In Singapore, the EIS cash payout can be paid only to the business that incurred the expenditure.9

7What the record shows

The record supports these points.

Ireland uses an advance notice for new and returning claimants, a valid claim requirement before payment, and case-by-case independent experts with procedural safeguards for the company.134
Singapore requires project-level information with the return for Form C filers, uses a standing Technical Advisory Panel, and offers an optional assurance framework that trades advance review for certainty.567
In both countries the company signs and bears the consequences of an incorrect claim.1710
Neither country's R&D claim documents identify the preparer or the basis of the preparer's fee.127

The record does not show how many claims in either country are prepared by outside advisers, how advisers are paid, or whether the controls described here have changed the outcome of reviews. IRAS has published outcome figures for 2018, and no comparable Irish figure was identified for this paper.5

References

Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29, section 766, subsection (7), and section 766C, subsections (9) to (12), (14), (16) and (17). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.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
Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 1, 2.5, 2.6, 8, 8.6.1, 8.6.2, 8.7 and 10. 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 29-02-05, Research and Development (R&D) Corporation Tax Credit: Appointment of expert to assist in audits (last updated August 2025), sections 1 to 3 and Appendices. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-05.pdf (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Research & Development (R&D) Tax Measures (last updated 13 August 2026), sections on R&D tax benefits, claiming, documentation, the Technical Advisory Panel and the 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
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 2.2, 3.1.1, 3.5.4, 11 to 14 and section 16. https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Research and Development (R&D) Claim Form (YA 2019 and onwards), Parts 1 to 6. https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/rnd-claim-form-(ya-2019-n-after).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 1 and 2 and the section on clients' bank and contact details. 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
Inland Revenue Authority of Singapore, Enterprise Innovation Scheme (EIS), sections on the cash payout, how to apply, and frequently asked question 6. https://www.iras.gov.sg/schemes/disbursement-schemes/enterprise-innovation-scheme-(eis) (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Penalties for Errors in Tax Returns (last updated 2 March 2023). https://www.iras.gov.sg/taxes/corporate-income-tax/form-c-s-form-c-s-(lite)-form-c-filing/penalties-for-errors-in-tax-returns (accessed 11 October 2026). Back

Cite this paper

Summary

1Summary

2Why compare these two systems

3Ireland

3.1The credit

3.2Before the claim: pre-filing notification

3.3The claim in Form CT1

3.4Records: the science test and the accounting test

3.5Expert consultation

3.6When a claim is not authorized

3.7Who acts for the company

4Singapore

4.1The deductions

4.2No general pre-approval or pre-filing notice

4.3The R&D Claim Form

4.4Documentation

4.5Review and the Technical Advisory Panel

4.6The R&D Assurance Framework

4.7Controls on the EIS cash payout

4.8Penalties

4.9What IRAS has published about outcomes

5The two systems compared

6What the controls do not address

7What the record shows

References

About this paper

Cite this paper

Summary

1Summary

2Why compare these two systems

3Ireland

3.1The credit

3.2Before the claim: pre-filing notification

3.3The claim in Form CT1

3.4Records: the science test and the accounting test

3.5Expert consultation

3.6When a claim is not authorized

3.7Who acts for the company

4Singapore

4.1The deductions

4.2No general pre-approval or pre-filing notice

4.3The R&D Claim Form

4.4Documentation

4.5Review and the Technical Advisory Panel

4.6The R&D Assurance Framework

4.7Controls on the EIS cash payout

4.8Penalties

4.9What IRAS has published about outcomes

5The two systems compared

6What the controls do not address

7What the record shows

References

About this paper

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