Compare R&D tax incentives in seven countries
The headline rules for the United States, United Kingdom, Ireland, Canada, Australia, New Zealand and Singapore, side by side. Each row links to the country guide and its official sources.
At a glance
Benefit type, refundability, pre-registration and deadline for each scheme.
| Income tax credit20% regular or 14% alternative simplified | |
| Expenditure credit20%, taxable. ERIS for loss-making R&D intensive SMEs | |
| Corporation tax credit30%, 35% for periods with a return due on or after 23 September 2027 | |
| Investment tax credit35% enhanced on up to C$6 million, 15% basic | |
| Tax offsetCompany tax rate plus an 18.5% premium, or plus 8.5% or 16.5% | |
| Tax credit15% of eligible expenditure | |
| 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 |
Rates and benefit type
Headline rates and the limits that shape them.
| Country and scheme | Benefit type | Headline rates | Limits and thresholds |
|---|---|---|---|
United StatesResearch credit, IRC section 41 | Income tax credit | 20% regular credit or 14% alternative simplified credit (15.8% or 11.06% if the reduced credit is elected) | Payroll tax election of up to US$500,000 a year for qualified small businesses |
United KingdomMerged RDEC scheme and ERIS | Expenditure credit | 20% expenditure credit. ERIS: extra 86% deduction and a payable credit of up to 14.5% of the surrenderable loss | ERIS needs R&D intensity of at least 30%. Payable credit capped at £20,000 plus 300% of PAYE and National Insurance |
IrelandR&D corporation tax credit | Corporation tax credit | 30% of qualifying expenditure, 35% where the corporation tax return filing date is on or after 23 September 2027, which typically means accounting periods ending on or after 31 December 2026 | First instalment: the greater of 50% of the claim or a fixed threshold: €75,000 for periods commencing on or after 1 January 2025 that end before 31 December 2026; €87,500 where the 35% rate applies |
CanadaSR&ED tax incentives | Investment tax credit | 35% enhanced credit, 15% basic credit | Enhanced rate on up to C$6 million of expenditure a year |
AustraliaR&D Tax Incentive | Tax offset | Corporate tax rate plus an 18.5% premium (refundable), or plus 8.5% or 16.5% (non-refundable) | Refundable below A$20 million turnover. Offset for expenditure up to A$150 million a year. Minimum spend A$20,000 |
New ZealandR&D Tax Incentive | Tax credit | 15% tax credit | Minimum NZ$50,000 and maximum NZ$120 million of eligible expenditure a year |
SingaporeEnterprise Innovation Scheme (EIS) | Enhanced deduction | 400% deduction on the first S$400,000 of staff costs and consumables for qualifying R&D carried out in Singapore, each Year of Assessment from YA 2024 to YA 2028, 250% above | Cash payout on up to S$100,000 of expenditure, S$20,000 maximum per Year of Assessment |
Refundability
Whether a company can receive the benefit as cash, and on what terms.
| Country and scheme | Refundable | How it works |
|---|---|---|
United StatesResearch credit, IRC section 41 | No | Not refundable. Qualified small businesses can apply up to US$500,000 a year against payroll tax, claimed on Form 8974. |
United KingdomMerged RDEC scheme and ERIS | Yes | Payable, capped at £20,000 plus 300% of relevant PAYE and National Insurance liabilities. ERIS gives a payable credit to loss-making R&D intensive SMEs. |
IrelandR&D corporation tax credit | Yes | Paid in three annual instalments, as an offset against tax or a repayment. |
CanadaSR&ED tax incentives | Yes, for most CCPCs | For most CCPCs at the enhanced rate, 100% of the credit on current expenditure and 40% on capital expenditure. Unused credits can be carried back 3 years or forward 20. |
AustraliaR&D Tax Incentive | Yes, under A$20 million turnover | The refundable offset applies to companies with aggregated turnover under A$20 million. |
New ZealandR&D Tax Incentive | In some cases | Refundable in some cases, with caps that include labour-related taxes. |
SingaporeEnterprise Innovation Scheme (EIS) | Optional cash payout | No refund of the deduction itself. An optional 20% cash payout is available to businesses with at least three full-time local employees, each earning a gross monthly salary of at least S$1,400. |
Registration and deadlines
What has to happen before the claim, and when the claim is due.
| Country and scheme | Before you claim | Claim deadline | Form or channel |
|---|---|---|---|
United StatesResearch credit, IRC section 41 | None | With the tax returnForm 6765 | Form 6765 with the income tax return |
United KingdomMerged RDEC scheme and ERIS | 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 | Company Tax Return, with an additional information form |
IrelandR&D corporation tax credit | In some casesAdvance notification for a first claim, or no claim in the previous 3 years | 12 months after the period ends | Corporation tax return |
CanadaSR&ED tax incentives | NoneOptional pre-claim approval since 1 April 2026 | 12 months after the return due dateForm T661, with Schedule 31 for corporations | Form T661, with Schedule 31 for corporations |
AustraliaR&D Tax Incentive | Yes, every yearRegister activities with the department | Register within 10 months of year endThen claim in the company tax return | Registration with the department, then the R&D tax incentive schedule with the company tax return |
New ZealandR&D Tax Incentive | Yes, approvalGeneral approval, or criteria and methodologies approval | 30 days after the return due dateSupplementary return | Supplementary return, after approval |
SingaporeEnterprise Innovation Scheme (EIS) | None | Filing due date of the tax returnClaimed in the return | Corporate income tax return. Cash payout through the EIS cash payout application |
Who administers each scheme
The authority responsible, with the main official guidance page.
| Country and scheme | Administered by | Main official guidance |
|---|---|---|
United StatesResearch credit, IRC section 41 | Internal Revenue Service (IRS) | Instructions for Form 6765, Credit for Increasing Research Activities |
United KingdomMerged RDEC scheme and ERIS | HM Revenue and Customs (HMRC) | R&D tax relief: the merged R&D expenditure credit scheme and enhanced R&D intensive support |
IrelandR&D corporation tax credit | Office of the Revenue Commissioners (Revenue) | Research and Development (R&D) Corporation Tax credit |
CanadaSR&ED tax incentives | Canada Revenue Agency (CRA) | Scientific Research and Experimental Development (SR&ED) tax incentives |
AustraliaR&D Tax Incentive | Department of Industry, Science and Resources and the Australian Taxation Office | Overview of the R&D Tax Incentive |
New ZealandR&D Tax Incentive | Inland Revenue | Research and development tax incentive |
SingaporeEnterprise Innovation Scheme (EIS) | Inland Revenue Authority of Singapore (IRAS) | Enterprise Innovation Scheme (EIS) |
By topic
Open a topic to see all seven countries.
Rates and benefit typeHeadline rates and the limits that shape them.
20% regular credit or 14% alternative simplified credit (15.8% or 11.06% if the reduced credit is elected)
20% expenditure credit. ERIS: extra 86% deduction and a payable credit of up to 14.5% of the surrenderable loss
30% of qualifying expenditure, 35% where the corporation tax return filing date is on or after 23 September 2027, which typically means accounting periods ending on or after 31 December 2026
35% enhanced credit, 15% basic credit
Corporate tax rate plus an 18.5% premium (refundable), or plus 8.5% or 16.5% (non-refundable)
15% tax credit
400% deduction on the first S$400,000 of staff costs and consumables for qualifying R&D carried out in Singapore, each Year of Assessment from YA 2024 to YA 2028, 250% above
RefundabilityWhether a company can receive the benefit as cash.
Not refundable. Qualified small businesses can apply up to US$500,000 a year against payroll tax, claimed on Form 8974.
Payable, capped at £20,000 plus 300% of relevant PAYE and National Insurance liabilities. ERIS gives a payable credit to loss-making R&D intensive SMEs.
Paid in three annual instalments, as an offset against tax or a repayment.
For most CCPCs at the enhanced rate, 100% of the credit on current expenditure and 40% on capital expenditure. Unused credits can be carried back 3 years or forward 20.
The refundable offset applies to companies with aggregated turnover under A$20 million.
Refundable in some cases, with caps that include labour-related taxes.
No refund of the deduction itself. An optional 20% cash payout is available to businesses with at least three full-time local employees, each earning a gross monthly salary of at least S$1,400.
Registration and deadlinesWhat happens before the claim, and when it is due.
With the tax return
2 years after the period ends
12 months after the period ends
12 months after the return due date
Register within 10 months of year end
30 days after the return due date
Filing due date of the tax return
Who administers each schemeThe authority responsible, with its main guidance page.
Internal Revenue Service (IRS)
Instructions for Form 6765, Credit for Increasing Research ActivitiesHM Revenue and Customs (HMRC)
R&D tax relief: the merged R&D expenditure credit scheme and enhanced R&D intensive supportOffice of the Revenue Commissioners (Revenue)
Research and Development (R&D) Corporation Tax creditCanada Revenue Agency (CRA)
Scientific Research and Experimental Development (SR&ED) tax incentivesDepartment of Industry, Science and Resources and the Australian Taxation Office
Overview of the R&D Tax IncentiveInland Revenue
Research and development tax incentiveInland Revenue Authority of Singapore (IRAS)
Enterprise Innovation Scheme (EIS)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.
General information only, not tax, legal or accounting advice. Rules change and eligibility depends on your circumstances, so check the official guidance or speak to a qualified advisor before you claim.