Ireland's payable instalments and fee timing

1Summary

Ireland's research and development (R&D) corporation tax credit is claimed under sections 766C and 766D of the Taxes Consolidation Act 1997 for accounting periods beginning on or after 1 January 2023.1 A company claims the credit in its corporation tax return, within 12 months of the end of the accounting period in which the expenditure was incurred.2

The credit is not paid all at once. The law divides it into three annual instalments. For accounting periods with a specified return date on or after 23 September 2027, the first instalment is the greater of €87,500 (or the whole credit, if lower) and 50 percent of the credit. The second is three fifths of the balance, and the third is whatever remains.34 Revenue can examine a claim and make or amend an assessment after the credit has been paid or offset.4 Its general time limit for doing so is four years from the end of the chargeable period in which the return was filed, with exceptions.5

An adviser's fee can be set on a different timetable. This paper describes, in general terms and with illustrative round numbers, how a success fee calculated on the total credit may fall due before the company has received most of the credit, and before Revenue's period for review has passed. It sets out the case for success fees fairly, describes fee terms that follow the instalments, and states where data does not exist. It makes no recommendation about Irish law or practice.

2The Irish credit in outline

2.1Which provisions apply

Revenue's guidance on the credit, Tax and Duty Manual Part 29-02-03, explains that claims for accounting periods beginning on or after 1 January 2023 cannot be made under the older sections 766 and 766A. They must be made under section 766C (R&D expenditure generally) or section 766D (expenditure on buildings or structures used for R&D), and the definitions in sections 766 and 766A continue to apply to the new sections.1

The rate of credit is 30 percent of qualifying expenditure for accounting periods beginning on or after 1 January 2024. For accounting periods with a specified return date on or after 23 September 2027, the rate is 35 percent. Revenue explains that, in general, the 35 percent rate applies to accounting periods ending on 31 December 2026 or later.1 Revenue's own worked example shows €500,000 of qualifying expenditure giving a credit of €150,000 at 30 percent for a period ended 31 December 2025, and €175,000 at 35 percent for a period ended 31 December 2026.6

2.2How a claim is made

A claim under section 766C must be made within 12 months of the end of the accounting period in which the expenditure giving rise to the claim was incurred.2 It is made by completing the relevant sections of the corporation tax return, the Form CT1, through the Revenue Online System.7 A company that has not claimed the credit in any of its previous three accounting periods must first notify Revenue on a prescribed form 90 days before making the claim.4

No supporting R&D documentation has to be submitted with the return. Revenue states that supporting documentation may be requested later to verify that the claim is valid, and that in this respect claiming the credit is no different from claiming any other corporation tax relief or credit.7 The legislation provides that no amount of the credit is to be paid or offset unless a valid claim has been made, and defines a valid claim as one where all the information Revenue may reasonably require to determine whether, and to what extent, the credit is due has been provided.4

To support a claim, a company must be able to show two things, which Revenue calls the Science Test (the activity is qualifying R&D) and the Accounting Test (the costs have been properly tracked and accounted for).7

3How the credit is paid: three instalments

3.1The earlier rules

Payment by instalments is not new. Under the earlier rules in section 766, a company with unused credit could, after any offset against corporation tax of the preceding period, claim to have the remainder paid in three instalments. The first instalment was 33 percent of the unused credit, paid no earlier than the specified return date for the period in which the expenditure was incurred. The remaining excess was used against corporation tax for the next period, and any balance was then paid as further instalments not earlier than 12 and 24 months after that date.8

The amounts payable under those rules were limited by section 766B to the greater of the corporation tax payable by the company for accounting periods ending in the 10 years before the relevant period, and the company's payroll liabilities for the relevant period and the preceding accounting period. That limit ceased to apply to claims under section 766(4B) where the specified return date is on or after 23 September 2023.8 Revenue's Notes for Guidance on section 766C do not describe a limit of this kind for claims under the current section.4

3.2The current rules

Under section 766C, the amount a company claims is payable in three annual instalments.4 For each instalment, the company must specify on its Form CT1 whether the amount, or any portion of it, is to be treated as an overpayment of tax and offset against its tax liabilities, or paid to the company by Revenue.6

The specification for the first instalment is made on the return for the accounting period in which the expenditure was incurred. The specification for the second instalment is made on the return for the next accounting period, and the specification for the third on the return for the period after that.6 Revenue's example is a company with expenditure in the year ended 31 December 2025 that files its return in September 2026: it specifies the first instalment on that return, the second on the return for the year ending 31 December 2026, and the third on the return for the year ending 31 December 2027.6

The instalment amounts depend on the accounting period. Figure 1 sets out the first instalment rule as Revenue describes it.

Figure 1. First instalment of the section 766C credit

Accounting periods	First instalment	Second instalment	Third instalment
Beginning on or after 1 January 2024 and ending on or before 31 December 2024	Credit payable in full in the first year up to €50,000	Not stated in the Notes for Guidance	Not stated in the Notes for Guidance
Beginning on or after 1 January 2025 and ending, in general, before 31 December 2026	Greater of €75,000 (or the credit, if lower) and 50 percent of the credit	Three fifths of the balance	The remaining balance
Specified return date on or after 23 September 2027 (in general, periods ending 31 December 2026 or later)	Greater of €87,500 (or the credit, if lower) and 50 percent of the credit	Three fifths of the balance	The remaining balance

Sources: Revenue, Tax and Duty Manual Part 29-02-03, section 2.3.1; Revenue, Notes for Guidance, section 766C(6).34

Revenue's worked examples show the effect. A credit of €100,000 for the period ending 31 December 2025 is paid as €75,000, then €15,000, then €10,000. A credit of €150,000 for the period ending 31 December 2026 is paid as €87,500, then €37,500, then €25,000. A credit of €80,000 for the period ending 31 December 2026 is paid in full as the first instalment, with nothing left for later years.3

3.3When each instalment becomes available

Revenue's guidance states that, on receipt of a valid claim for each of the three instalments during a 48 month period, it will pay or offset the credit as the company specifies.2 The Notes for Guidance describe section 766C(11) as requiring the credit to be paid or offset in full within 48 months of a valid claim being made.4

The first instalment becomes available for payment or offset on the filing of the return in which the claim is made.2
Where the following accounting period is 12 months long, the second instalment is payable on the filing of the return for that period. In other cases it is payable 12 months after the specified return date for the return in which the claim was made.4
Where the period after that is also 12 months long, the third instalment is payable on the filing of the return for that period. In other cases it is payable 24 months after the specified return date for the original return.4

For a company, the specified return date is set by reference to the day nine months after the end of the accounting period.9 Revenue's guidance refers to a specified return date of 23 September 2027 for, in general, accounting periods ending 31 December 2026.1 In practice, for a company with a calendar year, Revenue's example shows the return for the year ended 31 December 2025 being filed in September 2026.6

3.4Offset or payment

A company does not have to take the credit in cash. It may specify that an instalment is offset against its tax liabilities. Where the first instalment is offset against corporation tax for the accounting period, the offset may be taken into account in calculating preliminary corporation tax for that period and the next.3 Revenue's example is a company with a credit of €95,000 and corporation tax of €125,000 for the period ending 31 December 2026: if it offsets the first instalment of €87,500, its preliminary tax for the following period, based on 100 percent of the prior year's liability, is €37,500 rather than €125,000.3

This matters for the analysis below. Whether the company takes an instalment in cash or as an offset, the timing of that instalment is set by the legislation, not by the company or its adviser.

4How much of the credit arrives in the first year

Because the first instalment is the greater of a fixed amount and half the credit, the share of the credit available in the first year depends on the size of the claim. Figure 2 applies the formula for periods with a specified return date on or after 23 September 2027 to four illustrative credit amounts. The amounts are round numbers chosen for illustration; they are not drawn from any real claim.

Figure 2. Illustrative instalments for credits of different sizes (periods with a specified return date on or after 23 September 2027)

Illustrative credit	First instalment	Second instalment	Third instalment	Share available in year one
€80,000	€80,000	Nil	Nil	100 percent
€150,000	€87,500	€37,500	€25,000	About 58 percent
€200,000	€100,000	€60,000	€40,000	50 percent
€500,000	€250,000	€150,000	€100,000	50 percent

Calculated by the author from the instalment rule in section 766C(6) as described by Revenue.34 The €80,000 and €150,000 rows match Revenue's own examples.3

Three points follow from the formula.

A credit of €87,500 or less is available in full in the first year. For these claims the instalment rule makes no difference to timing.
For credits between €87,500 and €175,000, the first instalment is the fixed €87,500, so more than half the credit arrives in the first year.
For credits of €175,000 or more, the first instalment is exactly half the credit. The other half arrives over the following two years: 30 percent of the credit in the second instalment and 20 percent in the third.

5Revenue's review after payment

5.1Examination is not limited to the period before payment

The Notes for Guidance describe section 766C(16) as providing that nothing prevents Revenue from examining a claim, and making or amending an assessment, following the payment or offset of the credit, under the general assessing rules in Part 41A.4 In other words, receipt of an instalment does not mean that Revenue has accepted the claim.

5.2The general four year limit and its exceptions

Revenue's Notes for Guidance on section 959AA explain that a Revenue officer cannot make or amend an assessment for a chargeable period more than four years after the end of the chargeable period in which the return for that period was filed, where the return contained a full and true disclosure of all material facts. They also list cases in which an assessment can be amended at any time, including where the return did not contain a full and true disclosure.5 A Revenue officer's general right to make enquiries carries the same four year limit, subject to the same kinds of exception.5 Under section 959AD, Revenue may make an assessment at any time where a Revenue officer has reasonable grounds for believing that there is fraud or neglect.10

5.3What happens if a claim is found not to be due

If a claim is subsequently found not to be authorised by section 766C, the company may be charged to tax under Case IV of Schedule D, for the accounting period in respect of which the payment was made, on an amount equal to four times the amount not authorised. Losses, expenses and allowances cannot be set against that charge, and the amount carries interest from the date the credit was paid or offset.4 Revenue's worked examples of a clawback under section 766D apply tax at 25 percent to the Case IV amount; on a credit of €30,000, the Case IV income is €120,000 and the tax recovered is €30,000.11

Penalties may also apply. Revenue's guidance says that where an R&D compliance intervention results in a settlement, penalties apply in line with the legislation and the Code of Practice for Revenue Compliance Interventions, and publication may also apply.12 For the section 766C and 766D credits, a penalty under section 1077F(3) or (4) is chargeable on amounts offset by the company, amounts paid to it, and amounts claimed but not yet paid.12

5.4How Revenue reviews claims

Revenue's Code of Practice for Revenue Compliance Interventions, effective from 1 May 2022, sets out three levels of intervention. Level 1 interventions, such as requests to self review and profile interviews, aim to support compliance. Level 2 interventions, risk reviews and audits, challenge non-compliance. Level 3 interventions are investigations. Revenue states that these are levels, not a sequence, and that it may begin an intervention at any level.13

For R&D claims, Revenue may enlist qualified individuals with specialised knowledge in the relevant field of science or technology to report on whether the activities examined are R&D activities. Revenue must tell the company who it proposes to engage and what it intends to disclose, and the company may object where it believes there would be a genuine conflict of interest.14

5.5An illustrative timeline

The following timeline is illustrative. It assumes a company with calendar year accounting periods of 12 months, a claim for the year ending 31 December 2026, a return filed in September 2027, and a return that contains a full and true disclosure. Each date is derived from the rules cited above; it is not a statement about any real claim.

Figure 3. Illustrative timeline for a claim for the year ending 31 December 2026

Event	Illustrative timing	Basis
Qualifying expenditure incurred	Year ending 31 December 2026	Rate of 35 percent and €87,500 threshold apply in general to periods ending 31 December 2026 or later13
Claim made and first instalment available	On filing the return, by 23 September 2027	Section 766C(9) and (11)(a)124
Second instalment available	On filing the return for the year ending 31 December 2027	Section 766C(11)(b)4
Third instalment available	On filing the return for the year ending 31 December 2028	Section 766C(11)4
General four year limit for assessments ends	Four years after the end of the accounting period in which the return was filed: in this illustration, 31 December 2031	Section 959AA5

On these assumptions, the company receives the last instalment about two years after it makes the claim, and Revenue's general period for review runs for about two further years after that. Where the exceptions to the four year limit apply, there is no fixed end date.510

6Professional and regulatory rules on adviser fees in Ireland

6.1Revenue

We did not find any rule in the Irish tax legislation or in Revenue's guidance that governs how an adviser who prepares an R&D credit claim is paid. Revenue's guidance for agents and advisers states that Revenue does not operate any system for approving tax agents or advisers, and that a Tax Agent Identification Number is not an approval or endorsement of an entity's conduct, experience or abilities.15

The same guidance states that agents and advisers are not permitted to directly receive refunds in respect of their clients' business taxes.15 Any payment of the credit is therefore made to the company, and an adviser's fee is a separate matter between the company and its adviser.

6.2Chartered Accountants Ireland

The Code of Ethics of Chartered Accountants Ireland applies to its members, students, affiliates and member firms, and is adopted from the code of the International Ethics Standards Board for Accountants with additional material.16 In the version published on the Institute's website, whose Parts 1 to 4 apply from 1 March 2020, the general section on fees states that contingent fees are used for certain types of non-assurance services but might create threats to compliance with the fundamental principles, particularly a self-interest threat to objectivity, in certain circumstances.16 Factors relevant to that threat include the nature of the engagement, the range of possible fee amounts, the basis for determining the fee, and whether an independent third party is to review the outcome. Examples of possible safeguards include review of the work by someone not involved in it, and an advance written agreement with the client on the basis of remuneration.16

The Code prohibits contingent fees in narrower circumstances. A firm may not charge a contingent fee for an audit engagement, and a firm or network firm may not charge a contingent fee for a non-assurance service to an audit client in the circumstances the Code sets out.17 We did not find a provision in this Code that prohibits contingent fees for preparing an R&D credit claim for a client that is not an audit or assurance client.

6.3Irish Tax Institute

The Code of Professional Conduct and Recommended Best Practice Guidelines published on the Irish Tax Institute's website, issued under the name Irish Taxation Institute and taking effect from 15 September 2015, states that each member is responsible for setting their own fees and the way they are calculated, and that the Institute does not recommend any particular method of charging or any fee scales. It asks members to make sure the letter of engagement sets out an estimate of the proposed fees and the method for calculating them.18 We did not find a provision in this Code that prohibits contingent fees.18

7How fee timing can interact with the instalments

7.1Fee structures in general

An adviser's fee for an R&D credit claim can be set in several ways. In general terms, these include:

a fixed fee, or a fee based on time spent, agreed in advance and not linked to the amount of the credit;
a percentage of the credit claimed, invoiced when the claim is filed or when the first instalment becomes available;
a percentage of each instalment, invoiced as each instalment is paid or offset; and
combinations of these, such as a fixed element with a smaller contingent element.

We did not find any published data on which of these structures are used for Irish R&D claims, how common each is, or the percentages charged. This paper therefore does not say how any adviser charges. It describes how each structure lines up with the statutory timetable.

7.2A fee on the total credit, due at filing

Take the illustrative €500,000 credit from Figure 2, and an illustrative fee of 20 percent of the credit. The fee is €100,000.

If the whole fee is invoiced when the claim is filed, it falls due when the first instalment of €250,000 becomes available. The fee equals 40 percent of the cash or offset the company has at that point, although it is 20 percent of the total credit. The remaining €250,000 of credit arrives over the following two years.

On a smaller claim, the gap is smaller. For an illustrative credit of €150,000 and the same 20 percent rate, the fee is €30,000 against a first instalment of €87,500, or about 34 percent of that instalment. For a credit of €80,000, the whole credit arrives in the first instalment, and the timing of the fee and the credit coincide.

Figure 4. Illustrative 20 percent fee compared with each instalment

Illustrative credit	Fee at 20 percent of total credit	First instalment	Fee as a share of first instalment	20 percent of each instalment
€80,000	€16,000	€80,000	20 percent	€16,000, nil, nil
€150,000	€30,000	€87,500	About 34 percent	€17,500, €7,500, €5,000
€500,000	€100,000	€250,000	40 percent	€50,000, €30,000, €20,000

Calculated by the author from the instalment rule in section 766C(6).34 The fee rate is a round number chosen for illustration; it is not a reported market rate.

7.3A fee due before Revenue's review period has run

On the illustrative timeline in Figure 3, a fee invoiced at filing falls due in 2027. The company receives its last instalment in 2029, and Revenue's general period for making or amending an assessment runs, in that illustration, until the end of 2031.5

If Revenue later concludes that part of the credit was not due, the consequences for the company are set by statute: a Case IV charge on four times the unauthorised amount, interest, and possibly penalties, including penalties on amounts claimed but not yet paid.41211 The consequences for the adviser's fee are set only by the engagement terms. We did not find any statutory rule requiring an adviser to refund a fee where a credit is later reduced.

To illustrate: suppose that, after the second instalment, Revenue concludes that the qualifying expenditure was half the amount claimed, so that the credit due was €250,000 rather than €500,000. A fee of 20 percent on the credit as claimed was €100,000. A fee of 20 percent on the credit as finally allowed would be €50,000. Whether the difference is returned depends on the contract. Under a fee calculated on each instalment as paid, any instalment that Revenue does not pay generates no fee, but instalments already paid and later recovered raise the same question about refunds.

7.4A fee that follows the instalments

Fee terms could instead be written to follow the statutory timetable. In general terms, this can be done by calculating the contingent element on each instalment and invoicing it only when that instalment is paid or offset, or by holding back part of the fee until a set point in Revenue's review period. Either approach aligns the adviser's receipts more closely with the company's.

These terms have costs as well as benefits. The adviser waits longer to be paid, and carries the risk that the company ceases to trade, is sold or does not file later returns before the second and third instalments become available. The legislation does allow a successor company in the same group to take over the entitlement to remaining instalments in some circumstances, which shows that this situation is anticipated in the rules.4 Invoicing three times, and tracking which instalments have been paid or offset, also adds administration for both parties.

8The case for success fees

There are serious arguments for contingent fees in this setting, and they deserve to be stated in their strongest form.

Access. A company that has spent heavily on research may have little cash to pay a fixed fee before the credit arrives. A success fee lets it obtain specialist help without paying anything until the claim produces value. For a smaller company making a first claim, this may be the difference between claiming and not claiming.

Alignment with value. A fee that rises and falls with the credit ties the adviser's reward to the result the client wants. A client does not pay a large fee for a small or unsuccessful claim.

Risk sharing. Under a pure success fee the adviser bears the cost of work that produces no credit. Some companies prefer to transfer that risk.

Timing at filing reflects when the work is done. Most of an adviser's work, identifying projects, gathering evidence and preparing the claim, happens before the return is filed. A fee due at filing matches the period in which the adviser incurs the cost of the work, and a fee spread over three years shifts financing cost onto the adviser.

These arguments are about incentives and cash flow, not about the conduct of any adviser. Nothing in this paper suggests that advisers who charge success fees prepare claims with less care than others. The Irish professional rules described above recognize both sides: they do not prohibit contingent fees for this kind of work, but one of them identifies a self-interest threat to objectivity that can arise from them and lists safeguards.1618

What the instalment rules add to this debate is a point about timing. Where a fee is calculated on the total credit and falls due at filing, the adviser's payment can be fixed before the company has received most of the credit and before Revenue's period for review has passed, while the company alone bears the statutory consequences if the credit is later reduced.45 Fee terms that follow the instalments change that timing; they do not remove the other features of a contingent fee.

9What data exists

Revenue publishes detailed guidance on the instalment rules, with worked examples, and its Notes for Guidance describe the statutory provisions subsection by subsection.34 We did not find published data on:

how many claims are paid in one instalment and how many in three;
how many R&D claims Revenue reviews after payment, at which level of intervention, or with what result; or
the fee terms on which Irish R&D claims are prepared.

Without such data, it is not possible to say how often a fee falls due before most of a credit is paid, or how often a credit is reduced after a fee has been paid. The analysis in this paper is therefore structural: it shows how the statutory timetable and the fee structures described can line up, not how often any outcome occurs.

10What the record shows

The record shows that Ireland pays larger R&D corporation tax credits over three years. For periods with a specified return date on or after 23 September 2027, credits up to €87,500 are available in full in the first year, and for credits of €175,000 or more half is available in the first year, 30 percent in the second and 20 percent in the third.34

It shows that payment is not acceptance. Revenue may examine a claim and make or amend an assessment after the credit has been paid or offset, generally within four years of the end of the period in which the return was filed and without that limit in the cases the legislation sets out.4510 Where a credit is found not to be due, the company faces a Case IV charge, interest and possible penalties, including penalties on amounts not yet paid.41211

It shows that the timing of an adviser's fee is not set by Irish law. Revenue does not approve tax agents, and the professional codes reviewed leave fee methods to their members, with one identifying a self-interest threat from contingent fees and suggesting safeguards.151618 A fee calculated on the total credit and due at filing can therefore fall due before most of a large credit has been received and before Revenue's period for review has passed. Fee terms that follow the instalments are possible, with costs and benefits for both sides. No published data shows which terms are used.

References

Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), section 1, Introduction. 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 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 2.1 and 2.6. 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 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), section 2.3.1, Examples 4 to 8. 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, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29 (December 2025), section 766C, subsections (6), (7A), (9) to (12), (14), (16) and (17), pages 31 to 35. https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026). Back
Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 41A (December 2025), sections 959Z and 959AA, pages 16 to 17. https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part41a.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 2.2 and 2.3, Examples 1(a), 1(b) and 2. 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 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 8 and 8.6.2. 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, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 29 (December 2025), Chapter 2 overview and section 766(4B), pages 14 and 23. https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part29.pdf (accessed 11 October 2026). Back
Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 41A (December 2025), section 959A, definition of specified return date, page 3. https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part41a.pdf (accessed 11 October 2026). Back
Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 41A (December 2025), section 959AD, page 19. https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part41a.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 5.2, Example 23(a). 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 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), section 8.7, Penalty Application. 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, Code of Practice for Revenue Compliance Interventions (effective 1 May 2022), sections 1.1 and 1.1.1, pages 7 to 8. https://www.revenue.ie/en/tax-professionals/documents/code-of-practice-revenue-compliance-interventions.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 10, Consultation with other persons (Independent experts). 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 1 and 14, pages 3 and 10. 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
Chartered Accountants Ireland, Code of Ethics (Parts 1 to 4 applying from 1 March 2020), paragraphs 330.8 A1 to 330.8 A3, pages 69 to 70; and The Code of Ethics web page. https://www.charteredaccountants.ie/docs/default-source/technical-documents/ethics/code-of-ethics---december-2020.pdf?sfvrsn=e828ae7c_2 and https://www.charteredaccountants.ie/Ethics/The-Code-of-Ethics (accessed 11 October 2026). Back
Chartered Accountants Ireland, Code of Ethics (Parts 1 to 4 applying from 1 March 2020), paragraphs R410.10 and R410.11, pages 110 to 111. https://www.charteredaccountants.ie/docs/default-source/technical-documents/ethics/code-of-ethics---december-2020.pdf?sfvrsn=e828ae7c_2 (accessed 11 October 2026). Back
Irish Taxation Institute, Code of Professional Conduct and Recommended Best Practice Guidelines (taking effect from 15 September 2015), Article 11, Charging for Services, page 23, and Article 2.5.1, page 12. https://itiprod2storagegroup.blob.core.windows.net/files/Member%20Resources/ITI-Code-of-Professional-Conduct-effective-201509151.pdf (accessed 11 October 2026). Back

Cite this paper

Summary

1Summary

2The Irish credit in outline

2.1Which provisions apply

2.2How a claim is made

3How the credit is paid: three instalments

3.1The earlier rules

3.2The current rules

3.3When each instalment becomes available

3.4Offset or payment

4How much of the credit arrives in the first year

5Revenue's review after payment

5.1Examination is not limited to the period before payment

5.2The general four year limit and its exceptions

5.3What happens if a claim is found not to be due

5.4How Revenue reviews claims

5.5An illustrative timeline

6Professional and regulatory rules on adviser fees in Ireland

6.1Revenue

6.2Chartered Accountants Ireland

6.3Irish Tax Institute

7How fee timing can interact with the instalments

7.1Fee structures in general

7.2A fee on the total credit, due at filing

7.3A fee due before Revenue's review period has run

7.4A fee that follows the instalments

8The case for success fees

9What data exists

10What the record shows

References

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Summary

1Summary

2The Irish credit in outline

2.1Which provisions apply

2.2How a claim is made

3How the credit is paid: three instalments

3.1The earlier rules

3.2The current rules

3.3When each instalment becomes available

3.4Offset or payment

4How much of the credit arrives in the first year

5Revenue's review after payment

5.1Examination is not limited to the period before payment

5.2The general four year limit and its exceptions

5.3What happens if a claim is found not to be due

5.4How Revenue reviews claims

5.5An illustrative timeline

6Professional and regulatory rules on adviser fees in Ireland

6.1Revenue

6.2Chartered Accountants Ireland

6.3Irish Tax Institute

7How fee timing can interact with the instalments

7.1Fee structures in general

7.2A fee on the total credit, due at filing

7.3A fee due before Revenue's review period has run

7.4A fee that follows the instalments

8The case for success fees

9What data exists

10What the record shows

References

About this paper

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