Research and Development Capital Allowances

Last updated

Research and Development Capital Allowances, also known as RDAs, are a tax relief for businesses in the United Kingdom. They provide a 100 per cent first year capital allowance for research and development (R&D) capital expenditure. RDAs are the capital expenditure equivalent to the R&D tax relief scheme.

Contents

History

RDAs were the new name given to Scientific Research Allowances (which already existed) when the R&D Tax Credit scheme was launched in 2000. [1]

Overview

R&D Tax Relief only applies to revenue expenditure - generally, costs incurred on day-to-day operations, as opposed to expenditure on capital assets. However, RDAs allow relief for R&D capital expenditure as a capital allowance. RDAs make it possible to claim 100 per cent of the capital cost against taxable profits in the year the cost is incurred. This can deliver a helpful cash flow boost and a shortened payback period. A company should consider applying for RDAs if it has:

If any R&D revenue expenditure is capitalised in a company's accounts, it may still qualify for R&D Tax Relief or it may only qualify under RDAs. The accounts treatment when the asset is recognised on the balance sheet, as opposed to being written-off immediately in the profit and loss account, is not conclusive of whether the expenditure is revenue or capital for tax purposes. The distinction between revenue and capital expenditure in the context of its R&D tax treatment is critical. HMRC give details on how to distinguish between the two categories on their website [2] and in their CIRD manual. [3] Further detail can also be found in section 1308 of Corporation Tax Act 2009 [4] (which in turn updated section 53 of Finance Act 2004) [5] in relation to the revenue treatment of capitalised costs which relate to intangible assets.

How it works

RDAs are available for expenditure of a capital nature on R&D related to a company’s trade, e.g.:

So, unlike for R&D Tax Relief where only certain categories of expenditure can be claimed, RDAs are available on most expenditure incurred for the carrying out of, or provision of facilities for, R&D (except land and the cost of acquiring intellectual property). This includes building or premises assets which would not otherwise qualify for alternative forms of capital allowances (such as the Annual Investment Allowance).

This means that where a company acquires or builds property with the intention of using the property for the purposes of carrying on qualifying research and development, then most, if not all, of the expenditure involved will qualify for a 100 per cent capital allowance in the accounting period in which the expenditure is incurred.

Other technology tax reliefs

The Enterprise Investment Scheme (EIS) and Seed Enterprise Investment Scheme (SEIS) give generous income and capital gains tax relief to individuals who invest in small early stage businesses.

See also

There are various sources of information about RDAs.

Government working group

There is no formal government working group for RDAs. There is however a formal working group for R&D Tax Relief to assist and develop government thinking on R&D tax initiatives. Members of this Working Group include representatives from: HMRC and HM Treasury; industry; the financial services community including large accounting firms (PWC; Deloitte; KPMG; Ernst and Young) and independent consultants (MMP Tax); (Cashin Innovation Consulting); and representatives from professional bodies.

Related Research Articles

<span class="mw-page-title-main">Intangible asset</span> Asset that lacks physical substance

An intangible asset is an asset that lacks physical substance. Examples are patents, copyright, franchises, goodwill, trademarks, and trade names, as well as any form of digital asset such as software or cryptocurrency, including stablecoins in duress. This is in contrast to physical assets and financial assets. Intangible assets are usually very difficult to value.They suffer from typical market failures of non-rivalry and non-excludability. Today, a large part of the corporate economy consists of intangible assets, reflecting the growth of information technology and organizational capital.

A tax deduction or benefit is an amount deducted from taxable income, usually based on expenses such as those incurred to produce additional income. Tax deductions are a form of tax incentives, along with exemptions and tax credits. The difference between deductions, exemptions, and credits is that deductions and exemptions both reduce taxable income, while credits reduce tax.

Capital gain is an economic concept defined as the profit earned on the sale of an asset which has increased in value over the holding period. An asset may include tangible property, a car, a business, or intangible property such as shares.

<span class="mw-page-title-main">United Kingdom corporation tax</span> UK tax on UK-resident companies and companies with permanent establishments in the UK

Corporation tax in the United Kingdom is a corporate tax levied in on the profits made by UK-resident companies and on the profits of entities registered overseas with permanent establishments in the UK.

<span class="mw-page-title-main">Taxation in the United Kingdom</span> United Kingdom tax codes

In the United Kingdom, taxation may involve payments to at least three different levels of government: central government, devolved governments and local government. Central government revenues come primarily from income tax, National Insurance contributions, value added tax, corporation tax and fuel duty. Local government revenues come primarily from grants from central government funds, business rates in England, Council Tax and increasingly from fees and charges such as those for on-street parking. In the fiscal year 2014–15, total government revenue was forecast to be £648 billion, or 37.7 per cent of GDP, with net taxes and National Insurance contributions standing at £606 billion.

<span class="mw-page-title-main">Capital expenditure</span> Costs associated with the fixed assets

Capital expenditure or capital expense is the money an organization or corporate entity spends to buy, maintain, or improve its fixed assets, such as buildings, vehicles, equipment, or land. It is considered a capital expenditure when the asset is newly purchased or when money is used towards extending the useful life of an existing asset, such as repairing the roof.

<span class="mw-page-title-main">Consumption of fixed capital</span>

Consumption of fixed capital (CFC) is a term used in business accounts, tax assessments and national accounts for depreciation of fixed assets. CFC is used in preference to "depreciation" to emphasize that fixed capital is used up in the process of generating new output, and because unlike depreciation it is not valued at historic cost but at current market value ; CFC may also include other expenses incurred in using or installing fixed assets beyond actual depreciation charges. Normally the term applies only to producing enterprises, but sometimes it applies also to real estate assets.

The schedular system of taxation is the system of how the charge to United Kingdom corporation tax is applied. It also applied to United Kingdom income tax before legislation was rewritten by the Tax Law Rewrite Project. Similar systems apply in other jurisdictions that are or were closely related to the United Kingdom, such as Ireland and Jersey.

<span class="mw-page-title-main">Corporation tax in the Republic of Ireland</span> Irish corporate tax regime

Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.

<span class="mw-page-title-main">Inheritance tax in the United Kingdom</span> United Kingdom legislation

In the United Kingdom, inheritance tax is a transfer tax. It was introduced with effect from 18 March 1986, replacing capital transfer tax. The UK has the fourth highest inheritance tax rate in the world, according to conservative think tank, the Tax Foundation, though only a very small proportion of the population pays it. 3.7% of deaths recorded in the UK in the 2020-21 tax year resulted in inheritance tax liabilities. Other countries such as China, Russia and India have no inheritance tax, whilst Australia, New Zealand, Canada, Norway and Israel have all chosen to abolish succession taxes.

A self-invested personal pension (SIPP) is the name given to the type of UK government-approved personal pension scheme which allows individuals to make their own investment decisions from the full range of investments approved by HM Revenue and Customs (HMRC).

A qualifying recognised overseas pension scheme, or QROPS is an overseas pension scheme that meets certain requirements set by HM Revenue and Customs (HMRC). A QROPS can receive transfers of British pension benefits. The QROPS programme was part of British legislation launched on 6 April 2006 as a direct result of EU human rights requirements of the freedom of capital movement.

Capital allowances is the practice of allowing tax payers to get tax relief on capital expenditure by allowing it to be deducted against their annual taxable income. Generally, expenditure qualifying for capital allowances will be incurred on specified capital assets, with the deduction available normally spread over many years. The term is used in the UK and in Ireland.

Small Self Administered Scheme (SSAS) is a type of UK Occupational Pension Scheme.

<span class="mw-page-title-main">Double Irish arrangement</span> Irish corporate tax avoidance tool

The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history. By 2010, it was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement.

<span class="mw-page-title-main">Capital Allowances Act 2001</span> United Kingdom legislation

The Capital Allowances Act 2001 is an Act of the Parliament of the United Kingdom that governs how capital allowances are deducted from income taxable under the Income Tax Act 2007 and the Corporation Tax Act 2009.

A patent box is a special very low corporate tax regime used by several countries to incentivise research and development by taxing patent revenues differently from other commercial revenues. It is also known as intellectual property box regime, innovation box or IP box. Patent boxes have also been used as base erosion and profit shifting (BEPS) tools, to avoid corporate taxes.

Research and Development (R&D) Tax Credits are a UK tax incentive designed to encourage companies to invest in R&D. Companies can reduce their tax bill or claim payable cash credits as a proportion of their R&D expenditure.

The Research and Development Expenditure Credit (RDEC), introduced in 2013, is a UK tax incentive designed to encourage large companies to invest in R&D in the UK. Companies can reduce their tax bill or claim payable cash credits as a proportion of their R&D expenditure.

Creative Sector Tax Relief is a programme of tax incentives implemented in the United Kingdom in 2012 which encompass new incentives aimed at supporting the animation, high-end television and video game industries, in addition to the existing relief available for film production. The new reliefs are designed to promote culturally-relevant productions in the UK, to incentivise investment into UK productions that would otherwise take place outside the UK, and to support the necessary critical mass of infrastructure and skills in the UK for both today and in the longer term.

References

  1. HMRC, " ca60100"
  2. HMRC, "revenue V capital expenditure"
  3. HMRC, "CIRD81700"
  4. Corporation Tax Act, "Section 1308"
  5. Finance Act, "Section 53"
  6. Capital allowances Act,"Part 6"
  7. HMRC, "Capital allowances manual"
  8. HMRC, "revenue V capital expenditure"