R&D tax incentives for energy and cleantech
Energy and cleantech development qualifies in the ordinary way; what sets the sector apart is funding and capital. Where the work sits in materials, storage, grid and process development, what to exclude, how pilot plants are treated, and how each country handles grants and government co-funding.
Energy and cleantech development sits comfortably inside the definition of R&D in all seven schemes: a new cell chemistry, an inverter control strategy under fault conditions, a process route for a fuel. The science is rarely in doubt. What sets the sector apart is how the work is paid for and what it is done with. Projects commonly carry government grants and co-funding, and each country treats that money differently, from removing the funded costs to clawing back the benefit to ignoring the grant. The work is also capital intensive, so test rigs and pilot plants raise equipment questions a software claim never meets.
This guide follows the shape of the manufacturers guide, adds pilot and demonstration plants, and ends with each country's rule on grants.
What this guide covers
- Where technical uncertainty sits in materials, storage, power electronics and process routes.
- What to exclude, including installation of proven systems, compliance testing and exploration.
- Where the qualifying work ends in a pilot or demonstration plant.
- Evidence from test rigs and funder reports, and the equipment and energy costs often missed.
- Each country's rule on grants and co-funding.
Where to look
Materials and electrochemistry
Electrode materials, catalysts, membranes and electrolytes where a performance, degradation or cost target had not been reached by known compositions.
Storage systems
Battery management, thermal management and pack design where the combined behaviour of cells, cooling and control under real duty cycles could not be predicted and had to be tested. Assembling a pack from a supplier's reference design is not.
Power electronics and grid integration
Converter topologies and control strategies that had to hold stability or ride through faults in a configuration the standards and the vendors did not cover, established by simulation and hardware testing.
Fuels and process routes
Electrolysis, synthesis and conversion processes where yield, purity or efficiency at scale was uncertain, and scale-up from bench to pilot produced behaviour that had to be investigated. Generation components and building energy systems follow the same pattern: a new geometry, material or combination proven by test rather than by established design data.
Monitoring, forecasting and optimisation software follows each country's software rules as well; the industry examples module shows where the software boundary sits.
What to exclude
- Installation, commissioning and operation of proven systems to the manufacturer's specification.
- Site selection, feasibility, planning and permitting.
- Compliance testing and certification.
- Prospecting, exploring or drilling for minerals, petroleum or natural gas, which several schemes exclude expressly.
- Demonstration of commercial viability once the technical questions are answered.
Pilot and demonstration plants
A pilot plant can be the experiment, the place where the experiment happens, or a commercial asset, and the schemes treat each differently. Where the uncertainty can only be resolved at scale, building and running the pilot is part of the work: Australia treats building a prototype or pilot plant as eligible where it supports the experiment, or as part of the experiment where the prototype is its subject, and the United Kingdom treats prototypes as R&D where they resolve uncertainty, but not a first of class built for sale beyond the point the uncertainty is resolved. Where the plant also produces for sale or demonstrates viability, several schemes stop: Ireland excludes pilot plants that are not wholly and exclusively undertaken for R&D purposes, and New Zealand excludes preproduction activities such as demonstration of commercial viability, tooling up and trial runs. Where output is sold, Australia applies a feedstock adjustment whose feedstock inputs include energy, New Zealand allows materials that become part of products sold only to the extent the cost exceeds the amount derived, and Canada applies recapture rules. Record the date on which the technical questions were answered; the claim ends there even if the plant runs on.
Evidence in energy and cleantech
- A dated note at the start of each technical unknown stating the target, why existing data did not predict the result, and who judged that.
- Test rig logs, cycle test data and performance curves against the predicted values, including the failures.
- Failure analyses and the design changes that followed them.
- Pilot plant run logs with parameters, output and the question each run addressed.
- Grant milestone reports, which already describe the work but are written for a funder, so add the uncertainty framing a reviewer needs.
- Funding agreements and customer contracts, read for who bears the risk and owns the results.
- Time by engineer by project, captured monthly at the latest.
Costs often missed
Cells, materials and components destroyed in testing are eligible costs in most schemes. Test equipment is capital and the treatment varies widely; energy consumed in testing is a consumable in some schemes and an overhead in others.
| Country | Test equipment and capital items | Energy consumed in tests |
|---|---|---|
| United States | Supplies exclude land and property subject to depreciation; depreciation allowances on property used in research are research or experimental expenditures under section 174 | Utility costs are generally overhead and excluded, but extraordinary expenditures for utilities required for qualified research may be supplies |
| United Kingdom | Capital expenditure does not qualify for R&D tax relief; research and development allowances give a 100 percent allowance for capital expenditure on R&D | Consumable items include fuel and power consumed or transformed in the R&D |
| Ireland | Expenditure on plant and machinery qualifying for wear and tear allowances is qualifying expenditure to the extent the plant and machinery is used for R&D activities | Power directly consumed in the R&D may be apportioned; general overheads are excluded |
| Canada | Capital expenditures for property acquired on or after 16 December 2024 are again eligible SR&ED expenditures and qualified expenditures | Under the traditional method, overheads are allowable where directly related to the prosecution of SR&ED and would not otherwise have been incurred |
| Australia | An R&D entity can notionally deduct the decline in value of a tangible depreciating asset to the extent it is used for R&D activities during the income year | Electricity and other overheads are notionally deductible to the extent incurred on R&D activities, using a reasonable method of apportionment |
| New Zealand | Depreciation loss on tangible depreciable property used in performing R&D is eligible expenditure to the extent of the R&D use, excluding assets used to create other depreciable property | Power and other overheads are eligible to the extent they relate to R&D activities, apportioned on a reasonable basis |
| Singapore | Capital expenditure on plant and machinery used for R&D is not deductible under sections 14C and 14D but may qualify for capital allowances under section 19 or 19A | Consumables for the enhanced deduction exclude utilities; utilities qualify for the base 100 percent deduction only |
Getting started
List the year's projects with their funding sources and the equipment used, then run a project identification workshop on the technical content. For each project that survives the uncertainty test, model the grant rule before estimating the benefit, because the same grant can leave the claim untouched in one country and remove most of it in another. The finance module on grants works through the mechanics.
Illustrative example
Illustrative example. Kestrel Grid Systems Ltd, a hypothetical company, spent 500,000 on a battery thermal management project to keep cell temperatures within a stated band under a fast charging duty cycle that the supplier's reference design could not sustain. The engineers did not know whether any coolant path and control strategy could hold the band within the pack's weight limit. They built three rig configurations, cycled 200 cells to failure, rejected two configurations on temperature spread and fixed the third, at which point the work ended. The spend was 300,000 of engineering time, 120,000 of cells and materials destroyed in testing and 80,000 of test chamber costs. A government agency grant of 200,000 covered 40 percent. A further 50,000 spent installing a proven inverter at the demonstration site is excluded in every scheme. The grant now decides the claim. In a country that removes expenditure met by grant assistance, the candidate base falls to 300,000. In a country that applies a clawback, the base stays at 500,000 and an adjustment later removes the premium benefit on the 200,000 recouped. In the United Kingdom, the merged scheme contains no restriction for subsidised or grant-funded expenditure for accounting periods beginning on or after 1 April 2024, so the base stays at 500,000. The benefit at that country's rate applies to the resulting base.
Country differences
One rule per country, in the scheme's own wording, on grants and government co-funding. The country pages hold the detail.
| Country | Grants and co-funding rule | Country page |
|---|---|---|
| United States | Research is funded if payment to the taxpayer is not contingent on the success of the research, or if the taxpayer does not retain substantial rights in the research, and only to the extent of the funding. Contract research expenses are 65 percent of amounts paid for qualified research, 75 percent for payments to a qualified research consortium, and 100 percent for qualified energy research payments to eligible small businesses, universities and federal laboratories. | Industries: United States |
| United Kingdom | For accounting periods beginning on or after 1 April 2024 the merged scheme contains no restriction for subsidised or grant-funded expenditure. | Industries: United Kingdom |
| Ireland | Expenditure met directly or indirectly by grant assistance or any other assistance from the State, an EU institution or any other state is not qualifying expenditure. | Industries: Ireland |
| Canada | Qualified expenditures are reduced by government assistance, non-government assistance and contract payments that the claimant has received, is entitled to receive or can reasonably be expected to receive in respect of the expenditure. Provincial R&D tax credits are government assistance. | Industries: Canada |
| Australia | Where an R&D entity receives a recoupment from an Australian government agency for expenditure on which it has claimed the R&D tax offset, a clawback adjustment includes in assessable income an amount calculated so as to remove the premium benefit of the offset on the recouped expenditure. | Industries: Australia |
| New Zealand | Confirm the effect of any government co-funding on eligible expenditure before the general approval application is made. Ineligible expenditure includes interest, the cost of acquiring land or depreciable property, and expenditure on R&D performed for another person. | Industries: New Zealand |
| Singapore | R&D expenditure that is funded by a government grant or subsidy is not deductible, and the enhanced deductions apply only to the portion of qualifying expenditure borne by the company. Enterprise Singapore and EDB grants generally require the application to be approved before the project commences, and costs incurred before approval are not supported. | Industries: Singapore |
Related pages
- Guide: R&D tax incentives for manufacturers
- Technical Teams Program, Module 5: Industry examples
- In-House Finance Team Program, Module 5: Grants and subsidised expenditure
- Startups and Scale-ups, Module 3: Funding interactions
- Guide: qualifying versus non-qualifying activities
- Resource hub: eligibility
Educational material, not advice. Eligibility and the treatment of grants depend on the scheme, the funding agreement and the facts.
Sources
- Treasury Regulation section 1.41-4A, Qualified research for taxable years beginning before January 1, 1986eCFR
- R&D tax relief: the merged R&D expenditure credit scheme and enhanced R&D intensive supportGOV.UK
- Taxes Consolidation Act 1997, section 766Irish Statute Book
- Income Tax Act, section 127Justice Laws Website
- Income Tax Assessment Act 1997, Division 355Federal Register of Legislation
- Income Tax Act 2007, schedule 21BNew Zealand Legislation
- Research and Development (R&D) expenditureInland Revenue Authority of Singapore
Educational content only, not tax advice. Rules change and eligibility depends on your circumstances, so check the official guidance or speak to a qualified advisor before you claim. See the disclaimer.