After this module you will be able to locate the qualifying work inside a typical software, manufacturing, engineering, life sciences or food project, state the uncertainty, and say where the qualifying work stops. Every example is a labelled hypothetical with a fictional company; rates and country rules are on the country pages linked at the end.
What this module covers
- Where the technical uncertainty usually sits in each of five sectors, and where it does not.
- Five labelled examples, one per sector, with the record that shows the work in each.
- Where the qualifying work ends, and how to draw that boundary in money.
One question, five sectors
The question is the same in every sector: was there something a competent professional in the field could not know or work out from available knowledge, and did you do systematic work to find out? What differs is where that work hides, what gets wrongly swept in, and which record shows it.
| Sector | Where the qualifying work usually sits | What usually does not qualify |
|---|---|---|
| Software | Algorithms, architectures, performance and scalability work where the approach was uncertain; models that had to reach a required accuracy on your data | Configuration, integration through documented interfaces, interface design, maintenance |
| Manufacturing | Process development for a new material or tolerance; trial runs; scale-up; tooling and fixtures that had to be designed and tested | Routine production, quality control, commissioning equipment to the maker's specification, tooling with known outcomes |
| Engineering | Novel structural, geotechnical, materials or systems solutions with real uncertainty | Standard designs, code compliance, project management, work to a client specification with no unknown |
| Life sciences | Discovery, preclinical and clinical development, formulation, process scale-up | Post-approval marketing studies, routine release testing, regulatory paperwork |
| Food and drink | Formulation to achieve a technical result such as shelf life, stability or texture; process development | Taste, recipe variation, packaging appearance, seasonal variants |
Software
Illustrative example. Larkspur Software Ltd, a hypothetical company, needs to cut search latency on its document platform from two seconds to under 200 milliseconds at 50 million documents. The lead engineer records in a dated design note that the four documented indexing strategies had been benchmarked and none met the target at that scale. Over four months the team builds a benchmark harness, implements two strategies with modifications, abandons one at six weeks when it fails on long queries, designs a hybrid index and reaches 180 milliseconds. That is the resolution of a technological uncertainty; the tickets, the benchmark runs including the failures and the design note are the evidence. The admin interface rebuild, the billing integration through the provider's documented API and the cloud migration involved no unknown a competent engineer could not resolve with known techniques, and are not claimed. The three further months of hardening and rollout after the benchmark was met are outside. Several of the schemes restrict or exclude software built for your own internal administration, so check the country page before assuming an internal tool qualifies.
Manufacturing
Illustrative example. Corran Castings Ltd, a hypothetical company, takes an order for a component in an aluminium alloy it has not cast before and finds in the first pours that porosity exceeds the specification. Nobody calls this research, but the engineers did not know what combination of pouring temperature, die temperature and degassing would hold porosity within specification for this alloy in their dies. Over three months they run a structured series of trial pours, varying one parameter at a time, scrapping 60 castings and recording each on a trial run sheet with the parameters, the result and the engineer's name. Pour 61 meets the specification and the parameter set is fixed; that is where the qualifying work ends. The production run, the routine quality inspection and the commissioning of a new furnace to the maker's specification are not claimed. The trial run sheets and scrap records are the evidence.
Engineering
Illustrative example. Fenwick Structures Ltd, a hypothetical consulting engineer, designs a long-span composite floor using a timber species for which no published shear connector data existed. The uncertainty is whether a connector could achieve the stiffness and capacity the span required with this timber. The engineers design two connector geometries, test 12 specimens to failure, discard one geometry when it splits the timber at 60% of the target load, and derive design values from the second. The connector programme is the qualifying work; the test reports, calculation iterations and dated design notes are the evidence. The standard beam design, drawings, code compliance checks and project management are not claimed. Engineering services carry one more question: who bore the technical and financial risk, the consultant or the client. Several schemes decide who can claim on that basis, so read the country page before assuming the claim is yours.
Life sciences
Illustrative example. Oriel Biosciences Ltd, a hypothetical company, needs a liquid formulation of a protein therapeutic that stays stable for six months at room temperature, where the known formulations required cold storage. Whether any excipient combination could achieve that for this protein was unknown. The team screens eight combinations against a written protocol, with stability samples pulled at two week intervals; six fail by week eight, two hold through six months, one is selected. The protocol, lab notebooks, batch records and analytical results are the evidence, and the work ends when the six month data are in. Routine release testing of later batches against the fixed specification is not claimed. Life sciences work usually passes the eligibility test easily; what decides these claims is where the work was done and who funded it, especially for trials run through contract organisations.
Food and drink
Illustrative example. Holloway Foods Ltd, a hypothetical company, runs two projects on the same cereal bar in one year. The first reformulates the bar to taste more like caramel. None of it involves scientific or technological uncertainty: the question was what people prefer, and several schemes exclude changes of taste, style or appearance expressly. It is not claimed. The second sets out to keep the bar from going stale for twelve months in a new packaging film without its current preservative, where the available data on water activity and oxygen transmission did not predict the outcome. The technologists run accelerated and real-time storage trials on five formulation and film combinations, with moisture, texture and microbial testing at intervals; three fail at four and seven months, one reaches twelve. The formulation log, storage trial schedule and test results are the evidence, and the work ends when the twelve month data confirm the result.
Illustrative example
Illustrative example. Drawing the boundary in money for Corran Castings Ltd. The whole alloy project cost 400,000. The trial pour programme was three engineers for three months, 100,000, plus 20,000 of metal and consumables scrapped in the 60 trial castings. The production ramp cost 200,000 and the new furnace 80,000. The candidate base for the claim is the 120,000 spent resolving the porosity uncertainty, subject to each scheme's rules on consumed materials and equipment; the 280,000 of production and plant is outside the boundary. The benefit at that country's rate applies to the 120,000.
Across the seven countries
One rule per country, in its own words, that moves the line in one of these sectors; the industries pages walk through every sector.
| Country | A rule that moves the line | Industries page |
|---|---|---|
| United States | Research related to style, taste, cosmetic or seasonal design factors is excluded from qualified research. | Industries: United States |
| United Kingdom | A prototype built as a first of class for sale is not R&D beyond the point the uncertainty is resolved. | Industries: United Kingdom |
| Ireland | Verification testing undertaken to resolve design uncertainty may form part of qualifying R&D; validation testing against established requirements and regulatory testing are excluded. | Industries: Ireland |
| Canada | Experimental production, whose purpose is to evaluate the experimental development, is SR&ED; in commercial production with experimental development work, only the experimental work and the incremental cost of the work are SR&ED. | Industries: Canada |
| Australia | Developing, modifying or customising computer software for the dominant purpose of use by the entity for the internal administration of its business functions is excluded from core R&D activities. | Industries: Australia |
| New Zealand | Schedule 21 excludes from core activities preproduction activities such as demonstration of commercial viability, tooling up and trial runs. | Industries: New Zealand |
| Singapore | Software development qualifies as R&D only where there is novelty or technical risk in a scientific or technological sense; development using established methods, system integration, customisation and routine enhancements do not qualify even where the resulting product is new to the market. | Industries: Singapore |
Where to go next
Self-check questions
Answer each question, then open it to compare.
In the Corran Castings example, where does the qualifying work end and why?
Larkspur Software rebuilt its admin interface and added a billing integration in the same period as the indexing work. Why are those excluded?
Which of the two Holloway Foods projects qualifies, and what separates them?
Life sciences work usually passes the eligibility test. What usually decides those claims instead?
What is the primary evidence in a manufacturing claim, and what must it carry?
Why does the engineering example end with a question about the contract?
Official sources
- Guidelines on the meaning of research and development for tax purposesDepartment for Science, Innovation and Technology
- CIRD81960: software, the guidelines appliedHMRC internal manual
- Software-related activities and the R&D Tax IncentiveDepartment of Industry, Science and Resources
- SR&ED while Developing an Asset PolicyCanada Revenue Agency
- Treasury Regulation section 1.41-4, Qualified researcheCFR
- Research and Development (R&D) expenditureInland Revenue Authority of Singapore
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Educational content only, not tax advice. See the disclaimer.