Understanding HMRC's Evolving Approach to R&D Claims Processing

How the AIF is Reshaping R&D Tax Relief Claims

By Clear Tax Group

Since August 2023, the introduction of the Additional Information Form (AIF) has significantly reshaped the process for claiming R&D tax relief. This form requires companies to provide detailed evidence before submitting their tax returns, allowing HMRC to better “risk assess, process, and pay claims.”

How the AIF Has Changed HMRC's Approach

HMRC now risk-assesses all R&D claims. The AIF delivers crucial insights into a company’s R&D activities, associated costs, and the behaviors of advisors involved. As a result, HMRC has improved its ability to identify invalid or fraudulent claims.

Recent statistics show that 92% of claims were processed within 40 days in 2023–24, exceeding HMRC’s target of 85%. However, this enhanced system has also led some advisors to look for ways to bypass safeguards.

Advisor Involvement and HMRC’s Risk Measures

Accessing and submitting the AIF requires an agent code, which identifies the advisor completing the form. It also requires disclosure of:

• Any other advisors involved in preparing the claim

• Contact details of a senior officer at the claimant company

This transparency allows HMRC to trace all parties involved in the claim.

However, some advisors have tried to obscure their involvement—providing incorrect contact details or using alternate tax portals to avoid using their agent code.

Spotlight on Historical Advisors

Even when these tactics are used, HMRC is increasingly effective at detecting patterns. In many cases, claims are delayed for six months or longer, often when the company previously used advisors on HMRC’s internal "suspect list"—often for submitting fraudulent or exaggerated claims.

Even reputable accountants, assisting new clients with valid claims, have reported unexplained delays tied to the client's previous advisory history.

Implications for Reputable Advisors

HMRC’s risk process appears to extend beyond the advisors listed on the AIF, also considering past advisors used in earlier claims. While this helps prevent fraud, it can unintentionally affect legitimate businesses that have moved on from poor advisors.

Unfortunately, HMRC’s process for dealing with flagged claims is not transparent, leading to frustration as valid claims sit unresolved.

What This Means for Accountants and Advisors

If your clients are experiencing long R&D claim delays, it’s worth investigating their past claims and former advisors. Understanding this history can offer clarity on potential issues and red flags HMRC might be reviewing.

HMRC’s stricter processes emphasize the need for full transparency, accurate data, and detailed evidence. Proactive communication and proper preparation are now more critical than ever.

Need Support? We're Here to Help.

ClearTax Group can guide you through the complexities of HMRC’s R&D claim process. From preparing the AIF to managing correspondence with HMRC, we help ensure your claims are accurate, compliant, and submitted with confidence.

📞 Contact Us

ClearTax Group – R&D Tax Relief Specialists
📞 0161 224 5456
📧 [email protected]
🌐 www.cleartaxgroup.co.uk

Reach out today to avoid delays and maximise your R&D tax relief potential.