HMRC consultation: R&D tax relief advance clearance reform

Understanding advance clearance for R&D Tax relief

With HMRC’s consultation now underway, businesses must pay close attention to proposed changes around advance clearance for R&D tax relief. These developments are part of the government’s wider initiative to reduce error and fraud, increase certainty for claimants, and improve how companies engage with the Research and Development (R&D) tax relief process.

The consultation invites views on how clearances for R&D tax reliefs should be structured going forward, with the aim of enhancing the client experience and strengthening compliance within the scheme.

What is changing in the advance clearance process?

HMRC has operated an optional advance clearance application process for R&D tax relief for several years. However, due to extremely low uptake, this system is now under review, and HMRC is consulting on how best to reform it.

Under the proposals outlined in the consultation, HMRC is considering introducing a dual pathway system for advance clearance:

• Mandatory advance clearance for certain companies, based on criteria to be defined in legislation—such as industry sector, company size, and previous compliance history.
• Voluntary advance clearance remaining available to other businesses seeking assurance on eligibility or claim scope.

Potential impact on R&D tax relief claimants

If implemented, the proposed mandatory advance clearance could increase the administrative burden for some businesses, particularly those new to the regime or with more complex R&D activities. While the intent is to improve claim accuracy and reduce fraudulent submissions, these new compliance steps may require more time and resources to manage effectively.

How Rayner Essex can help – supporting you through the changing R&D landscape

As the R&D tax relief framework continues to evolve, following a string of recent reforms including the merged R&D scheme and enhanced relief for R&D-intensive SMEs; it’s more important than ever that businesses have a clear understanding of the scheme’s requirements. Ensuring that every claim is evidence-based, compliant with HMRC guidelines, and correctly structured, now demands greater precision and specialist expertise, critical to avoiding delays and disputes.

Get in touch for expert R&D support

As HMRC continues to reshape the R&D tax relief landscape, expert guidance is essential to avoid delays, disputes, or missed opportunities. Our dedicated R&D tax professionals work closely with you to help you understand the evolving rules, assess how the latest changes may impact the value of your claims, and align your R&D strategy with your broader tax, financial, and commercial objectives.

You can read more in our recent insights:

• The Merged R&D Scheme – All you need to know
• The treatment of contracted-out R&D

If you’re currently claiming or considering a claim for R&D tax relief, now is the time to review your processes. Get in touch with our R&D specialists for tailored advice and confident, compliant claims today.

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