Ask the Expert – R&D pre-notification: a step you can’t afford to skip

12 December 2024

If you’ve been following recent changes to R&D tax relief, you may have heard the term “pre-notification” cropping up. With HMRC adding new layers of compliance to the claims process, it’s easy to feel uncertain about what’s required. This week, we’ve asked John Thomson, Operations Manager at Visiativ Consulting, to explain what pre-notification means, why it matters, and how to ensure your claim stays on track.

Q | Hi John, pre-notification for R&D claims—what exactly is it and why is it making waves now?

Pre-notification is a new requirement introduced by HMRC for companies looking to claim R&D tax relief. Essentially, it’s a heads-up to HMRC that you intend to submit a claim. If your accounting period starts on or after 1 April 2023 and you haven’t claimed R&D relief in the last three years, you need to let them know within six months of your year-end. Sounds straightforward, right? The reality is that it’s catching a lot of businesses off guard.

Q | Why is this step causing confusion?

That’s because on paper, it looks deceptively simple: fill in a form before the deadline. But the tricky part is knowing when the rule applies. For instance, if you’re amending an older tax return (even one that started before April 2023) but submit that amendment after 1 April 2023, you might still need to pre-notify. Also, if HMRC has previously opened an enquiry and changed your return, that can trigger the need to pre-notify. These details aren’t always clear at first glance, and that’s where companies stumble.

Q | Have you seen many businesses struggle with this?

Plenty. At Visiativ, we work with clients daily who assume they can just file a claim as usual. When we mention pre-notification, their first response is often, “What’s that?” We’ve also had companies approach us after the fact, realising too late that they missed the pre-notification window. It’s frustrating for them because it can mean losing out on the relief they were banking on.

Q | Why did HMRC introduce this step?

HMRC is tightening up the rules to ensure claims are genuine and compliant. Pre-notification gives them a better line of sight into who’s planning to claim. It may feel like an extra hoop to jump through, but from their perspective, it’s about making R&D relief a more transparent and well-governed system.

Q | How can businesses avoid messing this up?

A: I’d say the key is awareness and timing. You need to know whether you fall into the category that requires pre-notification—don’t assume you’re in the clear just because you’ve claimed before or you think the new rules don’t apply to you. Working with reputable R&D tax advisors who stay on top of the latest HMRC guidance can be a lifesaver. They’ll run checks for you and guide you through each step of the process, so you don’t fall into these pitfalls.

Q | What’s the bottom line for companies planning their next R&D claim?

In a nutshell, don’t treat pre-notification as a minor detail—consider it a crucial compliance checkpoint. Get it right, and your claim moves forward smoothly. Get it wrong and you lose the ability to submit a claim for that year. Miss the last date of the claim notification period, and there are no other options and no second chances…

 

We hope John’s insights have been helpful – If you have any further questions about pre-notification or innovation funding in general, please get in touch with VISIATIV, and a representative will get back to you to discuss your unique needs and explain how we can assist.

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