R&D tax incentive training for seven countries

Plain-English guides, a side-by-side comparison and training programs for the R&D schemes in the United States, United Kingdom, Ireland, Canada, Australia, New Zealand and Singapore.

Choose your country Compare all seven

Verified against official guidance on 1 October 2026

Choose your country

Scheme, headline rates and the first step in each of the seven countries

All jurisdictions

United StatesUSResearch credit, IRC section 41

20% regular credit or 14% alternative simplified credit
Up to US$500,000 a year against payroll tax for qualified small businesses
No pre-registration. Claimed on Form 6765

United States guide United KingdomUKMerged RDEC scheme and ERIS

20% expenditure credit for periods beginning on or after 1 April 2024
ERIS for loss-making SMEs with R&D intensity of 30% or more
Claim notification needed if you have not claimed in the last 3 years

United Kingdom guide IrelandIER&D corporation tax credit

30% corporation tax credit, 35% for periods with a return due on or after 23 September 2027
Unused credit paid out in three instalments
Claim within 12 months of the end of the accounting period

Ireland guide CanadaCASR&ED tax incentives

35% enhanced credit on up to C$6 million of expenditure
Refundable on current expenditure for most CCPCs
File Form T661 within 12 months of the return due date

Canada guide AustraliaAUR&D Tax Incentive

Refundable offset of company tax rate plus 18.5% under A$20 million turnover
Non-refundable offset of company tax rate plus 8.5% or 16.5% above that
Register activities within 10 months of the end of the income year

Australia guide New ZealandNZR&D Tax Incentive

15% tax credit on eligible R&D expenditure
Minimum NZ$50,000 and maximum NZ$120 million a year
General approval due by the end of the 3rd month after the income year

New Zealand guide SingaporeSGEnterprise Innovation Scheme (EIS)

400% on the first S$400,000 of qualifying in-Singapore R&D staff and consumable costs (YA 2024 to YA 2028)
Optional cash payout of up to S$20,000 a year
No pre-registration. Claimed in the tax return

Singapore guide Compare all sevenBenefit type, refundability, pre-registration and deadlines in one table.

Credits
Tax offset
Enhanced deduction

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Where to start

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Finance teams

For finance managers, tax leads and accountants who build the numbers and file the claim.

Leadership

For CFOs, founders and directors who own the claim, sign it and choose the advisor.

Technical teams

For engineers, scientists and project leads whose work the claim describes.

Seven schemes at a glance

The headline rules in each country, taken from official guidance. Select a country for its full guide.

Full comparison

Country and scheme	Benefit type	Refundable	Pre-registration	Deadline
United StatesResearch credit, IRC section 41	Income tax credit20% regular or 14% alternative simplified	NoQualified small businesses can use up to US$500,000 a year against payroll tax	None	With the tax returnForm 6765
United KingdomMerged RDEC scheme and ERIS	Expenditure credit20%, taxable. ERIS for loss-making R&D intensive SMEs	YesPayable, capped at £20,000 plus 300% of PAYE and National Insurance	In some casesClaim notification within 6 months of the period end if no claim in the last 3 years	2 years after the period ends2 years from the end of the accounting period. Additional information form with every claim
IrelandR&D corporation tax credit	Corporation tax credit30%, 35% for periods with a return due on or after 23 September 2027	YesPaid in three instalments	In some casesAdvance notification for a first claim, or no claim in the previous 3 years	12 months after the period ends
CanadaSR&ED tax incentives	Investment tax credit35% enhanced on up to C$6 million, 15% basic	Yes, for most CCPCsCurrent expenditure fully refundable at the enhanced rate	NoneOptional pre-claim approval since 1 April 2026	12 months after the return due dateForm T661, with Schedule 31 for corporations
AustraliaR&D Tax Incentive	Tax offsetCompany tax rate plus an 18.5% premium, or plus 8.5% or 16.5%	Yes, under A$20 million turnover	Yes, every yearRegister activities with the department	Register within 10 months of year endThen claim in the company tax return
New ZealandR&D Tax Incentive	Tax credit15% of eligible expenditure	In some casesRefunds are capped, including by labour-related taxes	Yes, approvalGeneral approval, or criteria and methodologies approval	30 days after the return due dateSupplementary return
SingaporeEnterprise Innovation Scheme (EIS)	Enhanced deduction400% on the first S$400,000 of qualifying in-Singapore R&D staff and consumable costs (YA 2024 to YA 2028), 250% above	Optional cash payoutUp to S$20,000 a year, with conditions	None	Filing due date of the tax returnClaimed in the return

Benefit type by country
United States	Income tax credit20% regular or 14% alternative simplified
United Kingdom	Expenditure credit20%, taxable. ERIS for loss-making R&D intensive SMEs
Ireland	Corporation tax credit30%, 35% for periods with a return due on or after 23 September 2027
Canada	Investment tax credit35% enhanced on up to C$6 million, 15% basic
Australia	Tax offsetCompany tax rate plus an 18.5% premium, or plus 8.5% or 16.5%
New Zealand	Tax credit15% of eligible expenditure
Singapore	Enhanced deduction400% on the first S$400,000 of qualifying in-Singapore R&D staff and consumable costs (YA 2024 to YA 2028), 250% above

Verified against official guidance on 1 October 2026Full comparison

Programs

Training for companies and tax professionals, with an edition for each country. Register interest and we will contact you when your edition opens.

All programs

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For companies

Finance teams, founders and technical leads.

R&D Tax Fundamentals

How R&D tax incentives work, what counts as R&D, which costs are eligible, how a claim is built and what records support it, for anyone new to claiming.

In-House Finance Team Program

For finance managers, tax leads and accountants who run R&D claims internally or manage an external advisor: scheme mechanics, cost capture, apportionment, calculations, filing and reviews.

Leadership Briefing

A board-level overview for founders, directors and executives: the commercial case for claiming, the risks of a poorly prepared claim, how to govern the process and how to choose an advisor.

Technical Teams Program

For engineers, scientists and project leads whose work is the subject of a claim: why their input matters, how to identify uncertainty, record work as it happens and write the narrative.

Startups and Scale-ups

For founders and early finance hires: whether a claim is worth making, how to set up records from day one, how funding interacts with the incentive and what the first claim involves.

Hands working through a calculation with a calculator and pen.

For tax professionals

Advisors, accountants and in-house tax teams.

Advisor and Practitioner Program

For accountants and advisors who prepare claims for clients: legislation and guidance, eligibility analysis, advanced calculations, technical interviews, reports, disputes, and ethics, integrity and fee arrangements.

Country tracks

Each country's forms, deadlines and a worked example for practitioners.

For practices

Latest resources

Articles on eligibility, documentation, claims and advisor fees.

All resources

Industries

R&D tax incentives for energy and cleantech

Energy and cleantech development qualifies in the ordinary way; what sets the sector apart is funding and capital. Where the work sits in materials, storage, grid and process development, what to exclude, how pilot plants are treated, and how each country handles grants and government co-funding.

02 Oct 2026 · 9 min read

R&D tax incentives for food and agriculture02 Oct 2026 · Industries · 9 min read R&D tax incentives for engineering and construction02 Oct 2026 · Industries · 10 min read R&D tax incentives for life sciences02 Oct 2026 · Industries · 9 min read R&D tax incentives for software and SaaS02 Oct 2026 · Industries · 9 min read Browse by topic

Choosing an advisor

Advisors charge for R&D claims in different ways. Understand the fee structure and the engagement terms before you sign.

knowyourfees.orgInformation on how R&D advisory fees are structured.

Program for tax professionalsAdvisor and Practitioner Program

Program details

Register interest in a program

Programs open country by country. Tell us where you claim and what you want to learn.