Rd Tax Credits Matrix

---
name: rd-tax-credits-matrix
description: "Use this skill whenever a company asks about claiming a research and development tax credit, super-deduction, refundable cash incentive, or grant tied to R&D. Trigger on phrases like \"R&D credit\", \"R&D tax credit\", \"R&D super-deduction\", \"RDEC\", \"merged RDEC\", \"ERIS\", \"enhanced R&D intensive support\", \"SR&ED\", \"CIR\", \"Crédit d'Impôt Recherche\", \"Forschungszulage\", \"WBSO\", \"SLIM (Spain)\", \"credito ricerca\", \"patent box vs R&D\", \"R&D in OBBBA\", \"§174 capitalization\", \"§41 R&D credit\", \"JEI / JEU\", \"China R&D super-deduction\", \"India R&D §35\", \"Australia R&DTI\", \"USDA SBIR\", \"OECD frascati definition\", \"qualifying R&D\", or any request to compute eligibility, qualifying expenditure, and benefit value of an R&D incentive. Covers 25+ regimes including the post-2024 UK merged RDEC, US §174 capitalisation rules, France CIR, Germany Forschungszulage, Netherlands WBSO and Innovation Box interaction, China 175% super-deduction, India §35, Australia R&DTI, Canada SR&ED. Does NOT cover: patent box "
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/rd-tax-credits-matrix"
  jurisdiction: "GLOBAL"
  tax_year: "2025"
  last_updated: "2026-07-13"
---

# RD Tax Credits Matrix

## R&D Tax Credits / Super-Deductions Matrix v0.1

## What this file is

**This file is a content skill that loads on top of `cross-border-workflow-base`.** It maps the world's principal R&D tax incentives — credits, super-deductions, refundable cash incentives — as of mid-2025.

**Tax year coverage.** Current for **fiscal year 2025**, reflecting:
- **UK merged RDEC scheme** (FA 2024) for accounting periods beginning on or after 1 April 2024, replacing the small/mid-size R&D scheme with a single 20% above-the-line credit (~15% post-tax)
- **UK ERIS (Enhanced R&D Intensive Support)** for R&D-intensive loss-making SMEs (40%+ qualifying expenditure ratio) — 86% uplift + 14.5% credit on surrendered loss
- **US §174 R&D capitalisation** still in force per TCJA 2017 amendments (5-year domestic / 15-year foreign amortisation), with continued legislative pressure to restore immediate expensing
- **Germany Forschungszulage** raised to **35%** of eligible costs for SMEs (otherwise 25%) under the Wachstumschancengesetz (March 2024); annual cap of EUR 10 million per claimant
- **France CIR** unchanged at 30% (up to EUR 100m of expenditure; 5% above)
- **Netherlands WBSO** rates and ceilings updated annually
- **OECD BEPS Action 5** Modified Nexus interaction with R&D
- **Pillar Two** — R&D super-deductions can lower ETR below 15% and trigger top-up tax

**The reviewer is the customer of this output.** R&D claims face significant tax-authority scrutiny. Every output must be reviewed by a credentialed practitioner (typically R&D specialist firms or Big 4 R&D advisory) before any claim is filed.

## Section 1 — Scope statement

This skill covers:

- **Qualifying R&D definition** — OECD Frascati Manual and country adaptations
- **Eligibility tests** — taxpayer type, sector, claim history
- **Qualifying expenditure** categories
- **Benefit mechanism** — credit, deduction, refundable cash, super-deduction
- **Filing mechanics and audit risk**
- **Pillar Two interaction**
- **Patent box interaction** (cross-reference)

This skill does NOT cover:

- **Patent box / IP regime** computation — see `ip-patent-box-matrix.md`
- **Grant accounting** beyond reference
- **Country-specific R&D wage subsidies** that are not tax credits
- **Depreciation / amortisation** of capitalised R&D assets — see country corporate tax skills

## Section 2 — The Frascati definition of R&D

- **OECD Frascati Manual (2015 edition) definition of R&D** — R&D comprises creative and systematic work undertaken to increase the stock of knowledge, and to devise new applications of available knowledge. Five criteria, ALL of which must be met: 1. Novel — aimed at new findings; 2. Creative — based on original, not obvious, concepts and hypotheses; 3. Uncertain — outcome uncertain; 4. Systematic — planned and budgeted; 5. Transferable / reproducible — leads to results that could be transferred to / reproduced by others. Three types: Basic research — experimental or theoretical work without specific application; Applied research — original investigation for specific practical aim; Experimental development — systematic work using existing knowledge to produce new materials, products, processes.  _([T1] OECD Frascati Manual (2015 edition))_
- **Local regime adoption of Frascati** — Local regimes adopt Frascati with minor variations. Country-specific exclusions are common (e.g., UK excludes market research; France excludes routine quality control).  _([T1])_

## Section 3 — Country regime matrix

### 3.1 Europe

**Europe R&D regime matrix**  _(Section 3.1 Europe country regime matrix)_

| Country | Mechanism | Headline rate | Notable |
| --- | --- | --- | --- |
| **United Kingdom — Merged RDEC** | Above-the-line credit | **20% gross** (≈15% net) | Single scheme from periods beginning 1 Apr 2024. Subcontractor restriction (no overseas R&D from 1 Apr 2024 with limited exceptions). |
| **United Kingdom — ERIS (Enhanced R&D Intensive Support)** | SME loss surrender | **86% uplift + 14.5% credit** | Loss-making SMEs with ≥30% (reduced from 40% by FA(No.2) 2024) qualifying R&D expenditure ratio. |
| **France — CIR** | Refundable credit (4-year carryforward, refund if not used) | **30%** of qualifying expenditure to EUR 100m; **5%** above | Two-fold uplift for young innovative companies; doubling possible for grad-students hired. |
| **France — CII (Crédit d'Impôt Innovation)** | Credit | **30%** of qualifying innovation expenditure to EUR 400k | For SMEs; covers innovation prototyping (not pure R&D). Extended through 2027. |
| **France — JEI / JEU** | Combined tax + social contribution exemption | Up to 100% CIT exemption first year; 50% second year | Young Innovative Enterprises < 8 years old, R&D-intensive. |
| **Germany — Forschungszulage** | Cash subsidy via tax credit | **25%** (large) / **35%** (SMEs since March 2024) | Cap: EUR 10m eligible expenditure per claimant per year (was EUR 4m). Refundable if no tax liability. |
| **Italy — R&D Credit (Credito d'imposta R&S)** | Credit | **10%** basic research; **5%** development; uplift to 15% for South + women + youth | Reduced from prior 12-50% rates. Combined with Italian Patent Box super-deduction. |
| **Spain — R&D Credit (Deducción I+D+i)** | Non-refundable credit + cash conversion option | **25%** (excess over prior 2-year average) + **42%** on the excess; total cap 50% of CIT; cash-out at 80% of credit | Spanish CIT |
| **Netherlands — WBSO** | Payroll tax reduction | **32%** of first EUR 350k of qualifying R&D wages; **16%** above (rates as updated 2025) | Reduces wage tax/social contributions of R&D employees. Stackable with Innovation Box. |
| **Belgium — Partial Withholding Exemption** | Payroll tax exemption | **80%** exemption on R&D wages for qualifying researchers | Stackable with Innovation Income Deduction. |
| **Belgium — R&D Investment Deduction** | Increased depreciation | **15.5%** investment deduction one-shot OR **22.5%** spread | Choice; combined with patent income deduction. |
| **Ireland — R&D Tax Credit** | Refundable credit | **30%** (raised from 25% in FA 2023) | Cash refund possible over 3 years. |
| **Poland — R&D Tax Relief** | Super-deduction | **100% deduction** of qualifying costs; **200%** for wage costs (loss possible) | Combined with IP Box. |
| **Czech Republic — R&D Deduction** | Deduction | **100%** uplift (200% total) of qualifying expenditure | Multi-year carryforward. |
| **Romania — R&D Super-Deduction** | Super-deduction | **50% uplift** (150% deduction) | Plus 16% credit for certain expenses. |
| **Hungary — R&D Super-Deduction** | Super-deduction | **300%** deduction of qualifying expenditure | Limited to entities with own R&D operations. |
| **Slovakia — R&D Super-Deduction** | Super-deduction | **100% uplift** (200% deduction) | Plus 25% increase year-over-year. |
| **Portugal — SIFIDE II** | Credit | **32.5%** basic + uplift to 50% for incremental expenditure | Specific innovation funds. |
| **Norway — SkatteFUNN** | Credit | **19%** SMEs; **19%** large companies | Cap NOK 25m per project. |
| **Sweden — R&D Payroll Relief** | Payroll tax reduction | **20%** of R&D wages, cap SEK 1.5m/month | Plus general tax depreciation for R&D capex. |
| **Denmark — R&D Super-Deduction** | Deduction | **108%** of R&D expenses through 2025 (down from 130%); refundable for loss-makers up to DKK 25m | Negotiated annual extensions. |
| **Finland — R&D Combined Deduction** | Deduction | **150%** general R&D deduction + **50%** R&D wage uplift (combined max 200%) | Plus payroll tax relief |

### 3.2 Americas

**Americas R&D regime matrix**  _(Section 3.2 Americas country regime matrix)_

| Country | Mechanism | Headline rate | Notable |
| --- | --- | --- | --- |
| **United States — §41 R&D Credit (Federal)** | Non-refundable credit | **20%** regular method (over base period); **14%** ASC simplified | Plus 6% payroll tax offset for QSBs. §174 capitalisation 5/15 years amortisation continues in 2025. |
| **United States — State R&D Credits** | Various | 1.5% (NY)-15% (CA additional) | Stackable with federal |
| **Canada — SR&ED** | Refundable / non-refundable credit | **35% refundable** for CCPCs on first CAD 3m; **15% non-refundable** above and for non-CCPCs | Provincial top-ups in ON, QC, BC, MB, NS, SK |
| **Mexico — R&D Tax Credit** | Credit | **30%** of incremental R&D expenditure | Limited budget; advance allocation required |
| **Brazil — Lei do Bem** | Super-deduction + accelerated depreciation | **60-80%** of R&D expenditure deductible (additional to 100% expense); accelerated depreciation of equipment; reduced IPI on imports | Lucro Real taxpayers only |
| **Chile — R&D Credit (Ley 20.241)** | Credit | **35%** of qualifying R&D, refundable | Annual cap UF 15,000 |
| **Argentina** | Credit | Various sector schemes | Subject to currency and macro instability |
| **Colombia** | Deduction + credit | **100%** deduction + **25%** credit on R&D investment | Annual cap |

### 3.3 Asia-Pacific

**Asia-Pacific R&D regime matrix**  _(Section 3.3 Asia-Pacific country regime matrix)_

| Country | Mechanism | Headline rate | Notable |
| --- | --- | --- | --- |
| **Australia — R&DTI (R&D Tax Incentive)** | Refundable / non-refundable offset | **48.5%** refundable offset for aggregated turnover < AUD 20m; **38.5%** non-refundable for larger | Loss-making refunds available |
| **Japan — R&D Tax Credit** | Credit | **6-14%** of R&D expenditure (base); plus incremental + open innovation uplifts up to **30%** | SMEs higher base rate; multiple stackable categories |
| **China — R&D Super-Deduction** | Super-deduction | **100%** uplift (200% total deduction) for all industries (extended) | Permanent post-2021 expansion; manufacturing 200% historically maintained |
| **India — §35 Income Tax Act** | Super-deduction | **150%** in-house R&D (DSIR-approved); **100%** outside R&D | Reduced from 200% by Finance Act 2017. Plus weighted deduction for scientific research. |
| **Singapore — R&D Tax Deduction (§14C/§14D ITA)** | Super-deduction | **250%** of qualifying R&D expenditure in Singapore (raised from 150% in Budget 2023) | Cash payout option for SMEs |
| **South Korea — R&D Tax Credit** | Credit | **25-40%** SMEs; **15-40%** large (current vs base year) | Higher rates for "new growth engines" sectors |
| **Taiwan — R&D Investment Tax Credit** | Credit | **15%** of qualifying R&D, capped at 30% of CIT | Modified periodically |
| **Indonesia — R&D Super-Deduction** | Super-deduction | Up to **300%** for specified R&D categories | Pre-approval required |
| **Vietnam** | Deduction | 100% expensable; sector incentives separately | n/a |
| **Thailand — Smart Visa / BOI** | Various | Sector-specific | Combined with BOI incentives |
| **Malaysia — R&D Approved Status** | Deduction | **100%** in-house + special tax allowances | Pre-approval by MIDA |

### 3.4 Africa

**Africa R&D regime matrix**  _(Section 3.4 Africa country regime matrix)_

| Country | Mechanism | Headline rate |
| --- | --- | --- |
| **South Africa — §11D R&D Deduction** | Super-deduction | **150%** of qualifying R&D expenditure (pre-approval by DST required) |
| **Egypt** | Limited; sector schemes | n/a |
| **Kenya** | Limited; ICT and pharma sector incentives | n/a |
| **Nigeria** | 20% R&D credit (subject to approval) | n/a |

## Section 4 — Computation walk-through (UK merged RDEC example)

For a UK accounting period beginning on or after 1 April 2024:

### Step 1 — Qualifying activity test

- **BEIS Guidelines on R&D qualifying activity test** — Project seeks an advance in science or technology. Encounters scientific or technological uncertainty that a competent professional could not readily resolve. The advance must be a genuine advance in the relevant overall field, not just for the company.  _([T1] BEIS Guidelines on R&D (formerly DSIT Guidelines))_

### Step 2 — Qualifying expenditure

- **UK qualifying expenditure categories (CTA 2009 Part 13)** — Categories: Staff costs (gross salary, employer NICs, pension); Externally provided workers (EPWs) — restricted to UK workers post-2024; Subcontracted R&D — restricted to UK subcontractors post-2024 (limited overseas exception); Consumable items (utilities, materials transformed in R&D); Software, data, cloud costs (new from 2023); Payments to qualifying bodies (universities, charities, scientific research orgs); Externally licensed R&D resources. Capital expenditure NOT eligible for R&D credit but RDA / R&D Allowances available separately.  _([T1] CTA 2009 Part 13)_

### Step 3 — Compute the credit

- **Merged RDEC formula** — Credit = 20% × Qualifying R&D Expenditure. Credit is above-the-line (treated as taxable income). Net benefit (post-tax) = 20% × QRE × (1 - CT rate) ≈ 15% for main rate 25%. For ERIS (R&D-intensive loss-making SMEs): Uplifted loss = QRE × 186% (the 86% uplift); Surrendered loss credit = uplifted loss × 14.5% ≈ 27% net benefit.  _([T1])_

### Step 4 — Filing

- **UK filing mechanics and audit risk** — Notification of intent to claim required within 6 months of period end if no claim in past 3 years (CT600L). Additional Information Form (AIF) required for all claims from 8 August 2023. Claim period: 2 years from end of accounting period. Audit risk: HMRC has expanded R&D enquiry capacity since 2022; expect requests for technical narratives, project documentation, time records.  _(unsure)_

## Section 5 — Computation walk-through (France CIR example)

### Step 1 — Qualifying activity (CGI Art. 244 quater B)

- **France qualifying activity** — OECD Frascati criteria plus French specifics: Basic research, applied research, experimental development. Includes technological watch (max EUR 60k/yr) and patent expenses (deposit + maintenance + defence).  _([T1] CGI Art. 244 quater B; OECD Frascati criteria)_

### Step 2 — Qualifying expenditure

- **France qualifying expenditure categories** — Researcher and technician wages (with 50% uplift for operating costs — "frais de fonctionnement"); Depreciation of R&D assets; Subcontracted R&D — to approved bodies only; capped at 2× internal R&D spend OR EUR 12m; Patent costs; Standardisation expenses; Young doctors' wages — doubled for first two years post-graduation.  _([T1])_

### Step 3 — Compute the credit

- **CIR computation formula** — CIR = 30% × QRE up to EUR 100m + 5% × QRE above EUR 100m. For overseas territories: 50% on first slice. For young innovative companies: doubled.  _(unsure)_

### Step 4 — Use the credit

- **France CIR usage rules** — Offset against CIT due. Carry forward 3 years. Refund at end of year 4 if unused. Immediate refund for SMEs, JEI, young innovative companies, and loss-making companies in conciliation/safeguard. Pre-financing schemes (BPI France) advance the credit.  _(unsure)_

## Section 6 — US §174 capitalisation interaction

- **US §174 capitalisation rules** — TCJA 2017 amended IRC §174 effective for tax years beginning after 31 December 2021. Key effects: Domestic R&D expenditure must be capitalised and amortised over 5 years (mid-year convention). Foreign R&D expenditure must be capitalised and amortised over 15 years. Affects all R&D expenditure regardless of credit eligibility. §41 R&D credit base is independent of §174 capitalisation. Pending legislation has not restored immediate expensing as of mid-2025; bipartisan support exists but not enacted.  _([T1])_

[T2] Cash-flow timing of US R&D expenditure changed materially. R&D-intensive companies face significant Year 1 tax liabilities they did not have pre-TCJA. The §41 credit partially offsets but does not eliminate the cash impact.

## Section 7 — Pillar Two interaction

- **QRTC classification under Pillar Two** — Qualified Refundable Tax Credits (QRTCs) — i.e., refundable within 4 years — are treated as income in GloBE Income (not as reductions of Covered Taxes). This means refundable credits do not push ETR below 15%. Non-refundable / non-qualified credits reduce Adjusted Covered Taxes, lowering ETR. Heavy reliance on R&D super-deductions in low-tax jurisdictions can trigger top-up tax.  _([T1])_

[T2] By regime:
- US §41 — non-refundable beyond the QSB payroll offset → reduces Covered Taxes → ETR impact
- UK ERIS — credit refundable in 4 years → treated as income → no ETR push
- Germany Forschungszulage — refundable → treated as income
- France CIR — refundable post-4-yr → treated as income → no ETR push if claimed timely
- Australia R&DTI refundable offset — treated as income
- Canada SR&ED refundable (CCPC) — treated as income
- Italy super-deduction — non-refundable reduction → reduces Covered Taxes
- Hungary 300% super-deduction — non-refundable → reduces Covered Taxes
- Netherlands WBSO — refundable via payroll withholding → treated as income

## Section 8 — Edge cases and special rules

### 8.1 Subcontracted R&D and group transactions

- **Subcontracted R&D and group transaction rules** — Most regimes: Allow subcontracted R&D at restricted percentage of own R&D (commonly 65-80%). Restrict related-party subcontractor R&D to within OECD Modified Nexus Approach principles. The contracting party (the R&D commissioner) gets the credit; the contractor cannot also claim.  _(unsure)_

### 8.2 Grants and subsidised R&D

- **Grants and subsidised R&D offset rules** — Most regimes: Reduce the credit base by the amount of grant/state-aid funding received for the same expenditure. Some allow combining (Italy partially).  _(unsure)_

### 8.3 Foreign R&D performed abroad

- **Foreign R&D performed abroad rules by country** — UK (from 2024): generally exclude overseas R&D from claim. France: generally exclude unless within EEA + Norway / Iceland / Liechtenstein. US: include in §41 but §174 forces 15-year amortisation. Germany Forschungszulage: must be performed in Germany; EU sub-contracted possible under conditions.  _(unsure)_

### 8.4 Software development

- **Software development qualification by country** — UK: covered if seeking advance in computer science. US: §41 software covered if functional/process improvement is the goal. France: software R&D yes; routine custom development no.  _(unsure)_

### 8.5 Claim windows and amendments

**Claim windows and amendments by country**  _(unsure)_

| Country | Claim window |
| --- | --- |
| UK | 2 years post-period-end |
| US | 3 years from filing deadline; amended returns possible |
| France | 3 years post-period-end |
| Germany | 4 years generally |
| Canada SR&ED | 18 months from period-end |

### 8.6 Patent box stack

- **R&D credit and patent box stacking by country** — R&D credit and patent box are independent: France: CIR + IP Reduced Rate. UK: RDEC + Patent Box. Belgium: R&D investment deduction + Innovation Income Deduction. Italy: 110% iper-deduzione (now the "patent box replacement") combined with R&D credit. Netherlands: WBSO payroll relief + Innovation Box (the WBSO is partly a gateway condition for Innovation Box).  _(unsure)_

## Section 9 — Output specification

The reviewer brief must include:

1. **R&D project inventory** with technical narrative and Frascati test result per project
2. **Qualifying expenditure schedule** by category and project
3. **Credit/super-deduction computation** per regime claimed
4. **Refundable vs non-refundable analysis** and Pillar Two GloBE Income classification
5. **§174 amortisation schedule** (US claimants)
6. **Filing deadline calendar** per regime
7. **Grant / state-aid offset** schedule
8. **Patent box interaction** — confirm no double-counting; route IP income separately
9. **Audit risk assessment** — documentation status, prior enquiry history
10. **Reviewer questions** — open items flagged as [T2] or [T3]

## Section 10 — Self-checks

- [ ] Frascati criteria applied per project — novelty, creativity, uncertainty, systematic, transferable
- [ ] Qualifying expenditure categories per regime, not assumed by analogy
- [ ] Subcontractor restrictions applied (UK 2024+ overseas restriction)
- [ ] §174 capitalisation modelled separately from §41 credit (US claimants)
- [ ] Refundability tested for Pillar Two QRTC classification
- [ ] Grant / state-aid offset applied to credit base
- [ ] Patent box income excluded from R&D credit base where claimed under patent box
- [ ] Filing deadline plotted with safety margin
- [ ] Additional Information Form / equivalent technical documentation prepared
- [ ] Output flags every [T2]/[T3] item for reviewer judgement

## Section 11 — Prohibitions

- **Prohibitions list** — - Do not claim R&D credits for routine quality control, market research, social science research, or aesthetic/cosmetic activities — these fail the Frascati novelty test - Do not include grants in the qualifying expenditure base when the regime requires offset - Do not advise overseas subcontracting in the UK without confirming the limited 2024 exception applies - Do not stack R&D credit and patent box on the same IP income — Modified Nexus Approach requires separation - Do not treat the §41 US credit as solving the §174 capitalisation cash-flow timing problem — they are distinct - Do not ignore the OECD Pillar Two refundability classification — non-qualified credits push down the jurisdictional ETR  _(unsure)_

## Section 12 — Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. R&D claims face significant audit scrutiny across virtually every jurisdiction. Every output must be reviewed and signed off by a credentialed practitioner (R&D specialist firms, Big 4 R&D advisory, or local equivalent) before any claim is filed.

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-07-13. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `rd-tax-credits-matrix` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/rd-tax-credits-matrix. If neither is available, confirm every figure against the official source pages cited above before relying on it.