HMRC Changes - Pre-Notification Requirement

As a result of the recent reforms within HMRC, several areas of the R&D Tax Relief schemes changed with effect from the 1st April 2023. One such change is the requirement to notify HMRC in advance that you intend to make a claim.

Who needs to pre-notify?

You must pre-notify HMRC of your intention to claim in the following instances:

  • you’re claiming for the first time.
  • you’ve claimed for the previous tax year, but you did not submit that claim until after the last date of the claim notification period (the claim notification period ends 6 months after the end of the period of account).
  • your last claim was made more than 3 years before the last date of the claim notification period.

I.e., if a company submitted an R&D claim in 2021 and plans to do so again in 2024, it will not need to make a pre-notification (as the company made a claim within the previous three calendar years). However, if a company last claimed in 2020 and intends to make a claim in 2024, pre-notification will have to be submitted.

When do you need to notify HMRC of your intention to claim?

The earliest point at which a company can notify HMRC is the first day of the accounting period containing qualifying activity. The latest point at which you must notify is 6 months after the end of the accounting period containing qualifying activity.

For clarity, if the accounting period containing qualifying activity is 1st October 2023 to 30th September 2024, the notification must be submitted between 1st October 2023 and 31st March 2025.

What information is required?

The claim notification form will require the following:

  • The company’s Unique Taxpayer Reference (UTR).
  • The main senior internal R&D contact in the company who is responsible for the R&D claim.
  • The contact details of any agent involved in the R&D claim.
  • The accounting period start and end date for which you’re claiming the tax relief or expenditure credit.
  • The period of account, start and end date.
  • A summary of the high-level planned activities, and show how the projects meet the standard definition of R&D.

From the 1st August 2023 you must submit an additional information form to support all your claims for R&D tax relief or expenditure credit, either before or at the same time as the electronic submission of your CT600.

These changes will affect the way in which a claim is prepared. Therefore, it is of benefit to all companies currently undertaking R&D activities to speak with us to understand the impact of making a future claim to ensure you aren’t missing any important deadlines.


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