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Eligible expenditure: Ireland

What counts as qualifying expenditure for the Irish R&D credit: revenue expenditure wholly and exclusively on R&D, staff costs, plant and machinery, the limits on subcontracted and third level work, grants, and the costs the Act excludes.

IrelandLast reviewed 2 October 2026

The Irish credit is 30% of qualifying expenditure, 35% where the corporation tax return filing date is on or after 23 September 2027. Qualifying expenditure is expenditure incurred wholly and exclusively in carrying on qualifying R&D activities, which is a narrower phrase than it sounds: it includes most revenue costs of the R&D itself and the plant and machinery used in it, but caps what can be subcontracted, excludes grant-funded spend and leaves out costs that merely surround the R&D. This page sets out the categories, the apportionment rules and the exclusions. Buildings have their own credit, covered on the buildings and plant page.

Cost categories that qualify

CategoryRuleLimit
Revenue expenditure on R&D activitiesExpenditure incurred wholly and exclusively in carrying on qualifying R&D activities and allowable as a trading deductionNone
Plant and machineryExpenditure on plant and machinery used for R&D activities that qualifies for capital allowances, apportioned for other useApportioned
Subcontracted R&D to unconnected personsPayments to a person other than a university or institute to carry on R&D on the company's behalfThe greater of 15% of the company's own qualifying expenditure or €100,000
Third level institutionsPayments to a university or institute of higher education in the State or the EEA to carry on R&DThe greater of 5% of the company's own qualifying expenditure or €100,000

Staff and time

Emoluments of staff engaged in R&D activities, including salaries, bonuses, employer PRSI and pension contributions, are qualifying expenditure to the extent of the time spent on those activities. Revenue expects apportionment on a reasonable, documented basis; where an employee spends part of the time on R&D, only that part qualifies, and the Tax and Duty Manual warns against including administrative, managerial or supervisory time that is not itself R&D. Directors' emoluments follow the same rule.

Key employees can benefit directly: a company may surrender part of its credit to key R&D employees, who use it against their own income tax, subject to conditions including a 23% effective tax rate floor.

Contractors and subcontracted work

Where a contractor does R&D for the company, the company claims and the contractor does not, provided the company bears the cost and the work is carried on in Ireland or the EEA. The contract should show who commissioned the work, where it was performed and who owns the results.

Subcontracting is capped by reference to the company's own spend. Payments to unconnected persons to carry on R&D on the company's behalf qualify up to the greater of 15% of the company's own qualifying expenditure or €100,000, and payments to universities and institutes up to the greater of 5% or €100,000. The two caps are separate. The subcontractor must not itself claim the credit on the same work, and the company must notify an unconnected subcontractor in writing that it may not claim. Payments to connected persons for R&D are not subcontracted expenditure in the ordinary sense; group R&D is usually structured so that the entity carrying on the work claims.

The location rule applies to subcontractors too: the subcontracted activities must be carried on in Ireland or the EEA.

Materials, software and overheads

Materials and consumables used in the R&D qualify in full.

Software and cloud used in carrying on the R&D qualify as revenue expenditure, apportioned for other use. Software that is capital in nature is treated as plant and machinery.

Overheads qualify only where incurred wholly and exclusively in carrying on the R&D. Revenue accepts a reasonable apportionment of costs such as light, heat, power and consumables used in a laboratory, but not general overheads such as rent, insurance, accounting and administration. This is stricter than the UK and Australian rules, and companies moving between the regimes often overclaim overheads in Ireland.

Costs that are excluded

ExcludedTreatment
Expenditure met by grants or State or EU assistanceExcluded to the extent met by the grant
Expenditure relieved in another territoryExcluded
Interest, rent, rates, insurance, general administrationNot wholly and exclusively on R&D
BuildingsSeparate credit under section 766A
Subcontracting above the capsThe excess is not qualifying expenditure
Expenditure on activities outside Ireland and the EEAExcluded
Expenditure after the uncertainty is resolvedNot R&D; routine development

Illustrative example

Illustrative example. Liffey Software Limited, a hypothetical company with an accounting period ending 31 December 2025, has these costs for a qualifying project:

CostAmountQualifying
Six engineers, 60% of time on the project, emoluments and employer PRSI €720,000€720,000€432,000
Cloud test environments used only for the project€40,000€40,000
Test hardware (plant and machinery), 100% R&D use€30,000€30,000
Unconnected Dutch contractor for a component€120,000€100,000 (greater of 15% of €502,000, which is €75,300, or €100,000)
University College research agreement€60,000€60,000 (within the greater of 5% or €100,000)
Office rent and administration€90,000Nil
Enterprise Ireland grant towards the engineers' costs(€100,000)Reduces qualifying expenditure by €100,000
Qualifying expenditure€562,000

At 30% the credit is €168,600. The contractor's excess of €20,000 and the rent are deductible for corporation tax in the ordinary way but earn no credit.

Official sources

Educational content only, not tax advice. See the disclaimer.