HMRC CIRD Manual Updates on R&D Relief - Aug 2025
HMRC quietly pushed a fresh round of edits across parts of the Corporate Intangibles Research & Development (CIRD) manual at the end of August. Three pages matter for claimants and advisors: the avoidance introduction (CIRD97050), the “examining a claim” introduction (CIRD80520), and the practice note for ISBC & WMBC (CIRD80525). Below I’ve pulled the key changes and crucially what they mean in practice. GOV.UK+2
1/
HMRC re-states its stance on avoidance
and routes issues to central policy early
HMRC has refreshed its overview of how it handles avoidance within the R&D regime. If an officer suspects an artificial arrangement, they’re instructed to notify the R&D Policy team at an early stage, with challenges potentially brought under wider tax law and accounting principles - not just specific anti-avoidance rules. The page also points readers to sections on types of avoidance and statutory defences. The tone is clear: be alert without assuming guilt, but expect escalations when arrangements look contrived. GOV.UK
What this means for you
If your claim structure is unusual (group cost flows, intermediaries, novel funding), document the commercial substance, who did the R&D, and why the route was necessary.
Expect HMRC to use general legal/accounting challenges where appropriate - not just R&D-specific provisions. GOV.UK
2/
How HMRC will examine your claim:
the questions and the mindset
HMRC’s “examining a claim” introduction re-emphasises an open-minded approach but sets out the core questions officers expect you to answer in plain language. In short: articulate the advance in science or technology, the uncertainties faced, why the work wasn’t readily deducible to a competent professional, and when and how those uncertainties were overcome. The page also links to record-keeping guidance and flags that payable credit claims should be processed quickly, with partial payments considered where appropriate. GOV.UK
What this means for you
Frame technical narratives around baseline → advance → uncertainty → resolution, not around product features and benefits.
Tie staff time and costs to the uncertainty-resolving work; avoid the “assume everything is R&D then subtract marketing” approach.
Keep evidence proportional but decision-ready (design logs, test plans/results, code history, technical meeting notes). GOV.UK
3/
Practice note for ISBC & WMBC:
processing aims, AIF and claim notifications
HMRC’s practice note for the Individuals & Small Business Compliance (ISBC) and Wealthy & Mid-Sized Business Compliance (WMBC) teams spells out service expectations and some useful operational timing aims:
Processing aim: pay 85% of payable credits within 40 days or contact you within 40 days (subject to volume pressures). If HMRC decides not to pay because they think the claim may be incorrect, they aim to open an enquiry within 60 days of receipt. These are aims - not replacements for statutory enquiry time limits. GOV.UK
Additional Information Form (AIF): an AIF is required for every accounting period in which an R&D claim is made; HMRC uses it to triage reviews. GOV.UK
Claim notification: you may need to submit a claim notification if it’s your first R&D claim, if a previous claim was rejected, if you claimed by amending your return, or if you claimed for a period beginning on or after 1 April 2023. (Check the notification rules and deadlines before filing.) GOV.UK
During enquiries: HMRC will keep information requests to the minimum compatible with reasonable assurance but expect to speak with competent professional(s) and to request any extra records if new issues emerge. Communication during the enquiry is an explicit commitment. GOV.UK
What this means for you
File a complete AIF every time – in sufficient detail and ensure its filled in correctly.
Diarise the claim-notification requirement and deadline on new/returning claims (especially post-1 April 2023 periods).
Get enquiry-ready keep clear copies of the evidence you relied on and prepare to explain uncertainties succinctly.
4/
Where these updates fit in the 2025 refresh
HMRC’s CIRD manual has seen steady 2025 edits. Notably, on 22 May 2025 HMRC recorded “significant updates” and a complete change to the “Practice in ISBC and WMBC” section, tying directly to the separate practice note now published at CIRD80525. The pages above show 27 August 2025 as their latest update date, reflecting the ongoing tidy-up of guidance and links. GOV.UK
Practical next steps for claimants and advisors
- 1. Check if a claim notification is required for your upcoming filing and get it in early. GOV.UK
- 2. Strengthen the technical narrative around advance/uncertainty/resolution, and make sure time-and-cost mapping follows that logic. GOV.UK
- 3. AIF: mirror its structure in your working papers so an officer can navigate from AIF → evidence in one hop. GOV.UK
- 4. Sense-check structures: if your claim involves non-routine arrangements (subcontract chains, funding quirks, IP/licensing flows), document substance to head off any suggestion of artificiality. GOV.UK
Final word
The August edits don’t rewrite the rules, but they tighten the operational playbook: clearer service aims, firmer expectations on AIF/notifications, and an explicit route for escalating suspected avoidance. If you align your evidence and processes to this playbook, you can shorten reviews and lower enquiry risk.
View further insights from Innovation Tax here: https://www.innovationtax.co.uk/category/knowledge-bank/
HMRC CIRD Manual Updates Sources: HMRC CIRD manual pages on avoidance (CIRD97050), examining a claim (CIRD80520), and the ISBC/WMBC practice note (CIRD80525), plus the CIRD manual’s 2025 updates log.
Don’t let an HMRC enquiry slow your business down. With our expert guidance, you’ll have the support and confidence to navigate the process seamlessly and we will do our utmost to protect your R&D claim as long as it’s compliant.
