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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.

Verified against official guidance on 1 October 2026
Verified against official guidance on 1 October 2026

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.

At a glance

Benefit type, refundability, pre-registration and deadline for each scheme.

Benefit type by country
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 schemeBenefit typeHeadline ratesLimits and thresholds
United StatesResearch credit, IRC section 41
Income tax credit20% 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 credit20% expenditure credit. ERIS: extra 86% deduction and a payable credit of up to 14.5% of the surrenderable lossERIS 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 credit30% 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 2026First 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 credit35% enhanced credit, 15% basic creditEnhanced rate on up to C$6 million of expenditure a year
AustraliaR&D Tax Incentive
Tax offsetCorporate 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 credit15% tax creditMinimum NZ$50,000 and maximum NZ$120 million of eligible expenditure a year
SingaporeEnterprise Innovation Scheme (EIS)
Enhanced deduction400% 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% aboveCash 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 schemeRefundableHow it works
United StatesResearch credit, IRC section 41
NoNot 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
YesPayable, 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
YesPaid in three annual instalments, as an offset against tax or a repayment.
CanadaSR&ED tax incentives
Yes, for most CCPCsFor 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 turnoverThe refundable offset applies to companies with aggregated turnover under A$20 million.
New ZealandR&D Tax Incentive
In some casesRefundable in some cases, with caps that include labour-related taxes.
SingaporeEnterprise Innovation Scheme (EIS)
Optional cash payoutNo 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 schemeBefore you claimClaim deadlineForm or channel
United StatesResearch credit, IRC section 41
NoneWith the tax returnForm 6765Form 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 years2 years after the period ends2 years from the end of the accounting period. Additional information form with every claimCompany 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 years12 months after the period endsCorporation tax return
CanadaSR&ED tax incentives
NoneOptional pre-claim approval since 1 April 202612 months after the return due dateForm T661, with Schedule 31 for corporationsForm T661, with Schedule 31 for corporations
AustraliaR&D Tax Incentive
Yes, every yearRegister activities with the departmentRegister within 10 months of year endThen claim in the company tax returnRegistration 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 approval30 days after the return due dateSupplementary returnSupplementary return, after approval
SingaporeEnterprise Innovation Scheme (EIS)
NoneFiling due date of the tax returnClaimed in the returnCorporate 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 schemeAdministered byMain 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 OfficeOverview of the R&D Tax Incentive
New ZealandR&D Tax Incentive
Inland RevenueResearch 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.
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

RefundabilityWhether a company can receive the benefit as cash.
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 deadlinesWhat happens before the claim, and when it is due.
United StatesResearch credit, IRC section 41
None

With the tax return

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 ends

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 date

Form T661, with Schedule 31 for corporations

AustraliaR&D Tax Incentive
Yes, every yearRegister activities with the department

Register within 10 months of year end

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 date

Supplementary return, after approval

SingaporeEnterprise Innovation Scheme (EIS)
None

Filing due date of the tax return

Corporate income tax return. Cash payout through the EIS cash payout application

Who administers each schemeThe authority responsible, with its main guidance page.
United StatesResearch credit, IRC section 41
IrelandR&D corporation tax credit

Office of the Revenue Commissioners (Revenue)

Research and Development (R&D) Corporation Tax credit
AustraliaR&D Tax Incentive

Department of Industry, Science and Resources and the Australian Taxation Office

Overview of the R&D Tax Incentive
SingaporeEnterprise Innovation Scheme (EIS)

Inland 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.