Compare R&D tax incentives
How the schemes in the United States, United Kingdom, Ireland, Canada, Australia, New Zealand and Singapore differ, as one table across all seven and as regional summaries.
Verified against official guidance on 1 October 2026
All seven countries
Benefit type, rates, refundability, registration, deadlines and the administering body for each scheme, side by side.
Compare by region
Key differences between neighbouring schemes.
North America
- Both give a credit. Canada's enhanced credit is refundable for most CCPCs. The US credit is not, but qualified small businesses can use up to US$500,000 a year against payroll tax.
- Neither requires registration. Canada has offered optional pre-claim approval since 1 April 2026.
- US claims go with the return on Form 6765. Canadian claims are due 12 months after the return due date, on Form T661.
United Kingdom and Ireland
- Both give a credit that can be paid out: the UK subject to a PAYE and National Insurance cap, Ireland in three instalments.
- Both ask first-time claimants, and companies that have not claimed in the previous 3 years, to tell the tax authority in advance.
- The UK allows 2 years from the end of the accounting period to claim. Ireland allows 12 months from the end of the accounting period.
Asia Pacific
- Australia gives an offset linked to the company tax rate, New Zealand a flat 15% credit and Singapore an enhanced deduction.
- Australia requires annual registration and New Zealand requires approval before the claim. Singapore has no registration.
- Refunds: Australia below A$20 million turnover, New Zealand in some cases and Singapore through an optional cash payout.