SME R&D Enhanced Expenditure and 1 April 2023 changes

Hi

I’m looking at establishing the correct Corporation Tax treatment in relation to the enhanced deduction for SME R&D tax relief. Sage Corporation Tax adds back the net R&D expenditure, before deducting both the enhanced amount and the net expenditure incurred, i.e. addback of 100% and then a further deduction of 186%/230%. However, within this process the profit/loss after the net expenditure has been added back is time apportioned between tax years.

 

I’m aware other software has simply left the original expenditure amount as is, and then deducted the enhanced amount i.e. 86%/130%.

 

As far as I’m aware, historically either method resulted in the same outcome as the rates were consistent in each tax year (130%). However, with the rate change on 1 April 2023, the above calculations now result in two very different outcomes for an accounting period that straddles 1 April 2023.

 

It is my understanding that the correct treatment would be to simply deduct the enhanced amount, as that is what the legislation refers to (CTA 2009, S1044). Can you confirm if Sage follows a piece of legislation which supersedes this, or whether there is an intention to update the software to reflect this treatment?

 

Do let me know if you need any further information to assist with the above.

 

Kind regards

Tom

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    I would like to add to this in that Sage does not appear to be compliant with CIRD90500 as far as apportioning the loss goes.

    https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird90500

    I have spoken to HMRC and they have confirmed the loss in a company with a year end running from 1/1/23 - 31/12/23 does need to be apportionned i.e. 90 or 275 / 365 x the loss for the year. Sage just compares the surrenderable loss for the full year to the total enhanced expenditure - it does this automatically and there is no scope to overwrite the calculation. We have put the same data for a client with an unfiled SME R&D claim on Sage, into Xero tax, and Xero tax is arriving at a repayable claim tens of thousands of pounds lower due to a restriction of the loss in the first 3 months due to the loss being larger than the first 3m of enhanced expenditure. This is a really big problem and we will need to go back over our last year of claims through Sage and assess for non-compliance. I called the Sage helpline today and the advisor remoted on to my screen to compare Xero Tax, Sage Tax and looked at the HMRC link. Their response was "you are using the most up to date software version which has been out for more than a year and we have not received any complaints so we believe we are correct"!!! Er, sorry, what now?

  • 0 in reply to CKP

    Hi CKP,

    Thanks for using Community Hub.

    I have raised this with the relevant team for review, they advise that any changes that may be required will be included in the next update.

    Regards,

    Andy
    Sage UKI

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