Comparisons

In-house or outsourced R&D claim: what you can hand over and what stays with you

Keep the claim in-house if someone can own it every year and your activities are stable; outsource when the expertise or time is missing. Either way, the declaration, the records and the answer to an examination stay with the company. The deciding test is who will still understand the claim in two years.

Reviewed by George WalchFacts last verified

In-house claim and Outsourced claim side by side

In-house claim compared with Outsourced claim
FactIn-house claimOutsourced claim
Who drafts the registrationA finance, product or engineering lead at the companyAn adviser authorised in the customer portal
Cash costStaff time onlyThe adviser's fee, plus staff time for interviews and review
Knowledge after the claimStays in the business, unless the owner leavesSits with the adviser unless working papers are handed back
Consistency year to yearStrong if the same person owns itStrong if the same adviser stays; a switch needs a handover
Answering an examinationThe company, from its own recordsThe company, with the adviser's help if the engagement covers it
Main riskDescribing ordinary development as R&D without an outside checkA claim the company does not fully understand but must declare

Can you use both?

Most companies end up somewhere in between. Three hybrids work well: the company drafts and an outside reviewer checks before submission; an adviser drafts while a named person inside owns the evidence and the expenditure; or drafting software works from the company's records and an expert reviews the result. Write down who owns each step so nothing falls between the parties.

The choice is less "do it or buy it" than "which parts do we buy". Some parts of an R&D Tax Incentive claim can be handed to someone else. Three can never leave the company.

What always stays with you

  • The declaration. The company declares that the application is complete and correct, that it kept appropriate records, and that the activities meet the requirements.
  • The records. Keep them for five years after the claim. An adviser can organise them, but they are the company's records of its own work.
  • The answer to an examination. If the department examines the claim it notifies the company, can set out its concerns in a statement of issues, and gives 30 days to provide evidence it requests. A further 14 days is available if you ask before the 30 run out, and extensions to an evidence request are capped at 92 days in total. The notices go to the company.

The calendar each model creates

For a 30 June year end the registration is due by 30 April. Both models need the same milestones; what changes is who drives them.

WhenIn-houseOutsourced
During the yearThe owner checks that hypotheses, tests and results are being recordedDepends on the engagement; ask whether the adviser checks records during the year
July to DecemberThe owner drafts activities and costs themInterviews and document requests
Before 30 April (the department suggests a week ahead)Have any variation to add or significantly change an activity approvedThe adviser requests it, on the company's instructions
After submissionKeep the file ready for questionsGet the working papers back

After the deadline, variations are limited to removing, reclassifying or re-dating activities (without lengthening the period) and minor details; adding an activity is not among them. If the department makes a decision you disagree with, internal review must be requested within 28 days of being notified of it. Those clocks run against the company whoever prepared the claim.

The continuity problem

Multi-year core activities keep their registered names, and each year's text describes that year's open uncertainty and experiments. That only works if someone remembers last year. In-house, the risk is the owner leaving; outsourced, the risk is the adviser keeping the working papers. Either way, ask for a handover pack every year: the submitted registration, project and activity names, the apportionment method and the records each activity relies on.

Choosing

Keep it in-house when one person can own the claim year after year, the activities are stable and few, and someone outside can review it before you declare. Outsource when the claim is large, the structure is complex, or nobody has the hours. Partial outsourcing is common too: Rand, for example, drafts from the company's own records for its team and an Expert Reviewer to check, while the company keeps the declaration and submission. For the self-prepared end of the scale see Rand vs doing it yourself; for who to outsource to, see specialist vs accountant and the R&D tax incentive guide.

Frequently asked questions

How many people does an in-house claim need?
Usually one owner who learns the program, plus time from the technical leads for each core activity and from finance for the expenditure. The load peaks after year end, before the 10-month deadline, and again if the department or the ATO asks questions.
If we outsource, who signs the declaration?
The company. An adviser can be authorised to work in the customer portal, but the applicant declares that the information is complete and correct and that records were kept. That responsibility cannot be contracted away.
What should we get back from an outsourced provider each year?
The registration as submitted, the activity and project names, the expenditure working papers and apportionment method, and the list of records each activity relies on. With those, the next claim can be done by anyone.

Sources

  1. business.gov.au: Request an extension or variation on your R&D Tax Incentive application
  2. business.gov.au: Assuring integrity in the R&D Tax Incentive (evidence requests)
  3. business.gov.au: Decisions we make about applications (examinations and reviews)

The R&D Tax Incentive is a self-assessment program. This page is general information, not tax, legal or financial advice; eligibility depends on your circumstances and you should seek independent advice for them.