HMRC has published draft guidance on the new R&D expenditure credit for large companies (and small companies in some circumstances) for inclusion in the CIRD manual, together with draft notes and examples.
HMRC are asking for comments on the guidance by 31 January 2014 – see http://www.hmrc.gov.uk/drafts/rdec-oct-2013.htm for details of where to send any comments you have.
The guidance mostly follows the legislation, so there aren’t too many surprises. It does make it clear (as some conflicting advice had been received from HMRC previously) that the credit does increase quarterly instalment payments of corporation tax for a claimant company (where the company needs to make such instalment payments on account of corporation tax), compared to claiming an enhanced deduction (because the credit increases the taxable profits). You might think that there would be a corresponding reduction for the credit against tax, but the guidance notes that it is a stand alone credit and not treated a deduction in calculating the corporation tax liability – so it isn’t included in the calculation of instalment payments.
The guidance does go on to suggest that with some nifty timing, once a company has submitted a return and made a valid claim for the credit, it could use the credit available to be paid to it to set against instalment payments.