When HMRC introduced the Additional Information Form (AIF) last August, it was designed to allow much improved screening of R&D claims as it meant HMRC could check various details quickly, including any advisor(s) who assisted with the claim.

Before an advisor/agent can submit AIFs on behalf of its clients, it must first register for an agent services account with HMRC. If, however, a company wishes to submit its own AIF, then it can do so using its online tax account, accessed via the Government Gateway.

HMRC makes it very clear that using an agent services account is the only way advisors should be submitting AIFs on behalf of their clients:

“If you’re an agent. You must log in to your agent services account before you can complete an additional information form on your client’s behalf.

You should not use your client’s Government Gateway user ID or access their online tax account.”

This is to help ensure that HMRC has full visibility of who actually submitted the AIF and, if necessary, the details included on it with regards to which advisor prepared the claim can be cross-checked against the agent services account used for the submission, to ensure that they match.

However, we’ve heard from several companies now that their R&D advisor has asked to be set up as a user on the company’s online tax account which is either done manually, or by clicking on a emailed link.

This is very worrying, as it could allow an advisor to hide its involvement in an R&D claim – if it doesn’t log in using its own agent code then it can’t be identified that way and if it then doesn’t fill in the sections of the AIF which request advisor details then it cannot be identified that way either.

If you, or your clients, have engaged an R&D advisor who is insisting that they be set up as a user on the company’s online tax account, be wary as this might be a sign that it doesn’t want HMRC to know that it was involved with the claim.

If you have any questions on this blog or anything R&D related, please contact us at [email protected].

Posted: 20 Jun 2024