What is the Pre-Filing Notification for R&D Tax Credits?

Ireland's R&D tax credit scheme has become a cornerstone of the country's innovation strategy, offering businesses up to 35% relief on qualifying research and development expenditure.

But before you can claim these credits, you need to navigate the pre-filing notification (PFN) requirement. Miss this step, and you could lose your entire entitlement for that accounting period, regardless of how much qualifying R&D work you've undertaken.

What is the Pre-Filing Notification (PFN)?

The pre-filing notification is exactly what it sounds like: advance notice to Revenue that you intend to claim R&D tax credits for a specific accounting period. Think of it as raising your hand before you submit your actual claim.

Revenue introduced this requirement as part of their efforts to improve compliance and reduce fraudulent claims. By requiring companies to signal their intention to claim R&D credits in advance, Revenue can better allocate resources for reviewing claims and avoid last minute, spurious claims.

The PFN isn't your actual claim; it's a preliminary step that opens the door to making your full claim later. It's a relatively straightforward process, but the consequences of missing it are severe.

Who Needs to Submit a Pre-Filing Notification?

Understanding when you need to make a PFN is crucial, as the rules aren't uniformly applied to all companies.

You must make a pre-filing notification if:

1. You're claiming R&D tax credits for the first time – This applies to any company that has never previously claimed R&D tax credits under the scheme.
2. There's been a gap in your claims – If you've claimed R&D credits before but haven't made a claim in the last three accounting periods, you'll need to submit a PFN when you resume claiming.

These are the only two instances where you must submit a PFN, but any company is able to submit one if they want to.

When Do You Need To Submit the Pre-Filing Notification By?

The PFN must be made at least 90 days before the date that you submit your R&D tax credit claim. This timing is absolute; there's no flexibility or extension available.

For example:

Company A has an accounting period running from 1 January 2025 to 31 December 2025. It plans to submit its R&D tax claim on 31 March 2026. Therefore, Company A must send its PFN by 31 December 2025 (i.e., 90 days before).

The deadline to submit an R&D tax credit claim is one year after the end of the accounting period. If you’re claiming for a period ending on 31 December 2025, you have until 31 December 2026 to make that claim. Your PFN must be submitted at least 90 days before that deadline.

If Company A plans to leave its claim until the R&D tax credit deadline, which is one year after the end of the accounting period, then it must send off its PFN at least 90 days before then. If the deadline is 31 December 2026, the deadline to send the PFN is 90 days before, i.e., 2 October 2026.

The key takeaway here is to submit your PFN as soon as possible, so there’s absolutely no risk to your claim’s validity. If a company submits their PFN early enough, the actual R&D tax credit claim shouldn’t be a squeeze.

Sending off a PFN doesn’t mean you’re obligated to make a claim. You could always send off your PFN to Revenue, then decide not to claim for any reason.

How to Make a Pre-Filing Notification

The actual process of making a PFN is straightforward, though you must take care to include all the necessary fields.

The required information includes:

• Company name and tax reference number
• Accounting period for which you intend to claim
• Number of projects expected
• Number of employees working on R&D at the time of PFN submission
• Any grant-funded expenditure
• Brief description of your R&D activities
• Contact details for correspondence
• Any other information you may wish to provide to Revenue before submitting your claim

There’s no need for precise details yet. However, if your claim value or actual R&D activities change dramatically from what you said in the PFN, you should expect to defend those changes.

If you are claiming for capital expenditure, you need to submit two PFNs: one for your usual revenue expenditure under Section 766C and another for the capital expenditure under Section 766D.

For capitalised expenditure, you need to include:

• Confirmation that the building or structure qualifies for the R&D tax credit
• The proportion of the building or structure which is used for R&D over a period of four years
• Any grant funding for this building or structure
• Any other comments you want Revenue to know

The submission process is:

1. Prepare your notification letter – This is a Revenue template that must be filled in correctly. A letter prepared that doesn’t use the template may not be accepted.
2. Submit via appropriate channel – The PFN must be filed through MyEnquiries via ROS.
3. Retain confirmation – Keep records of when and how you submitted your PFN

What Happens If You Don’t Submit a PFN?

The consequences of missing the PFN deadline are severe and non-negotiable. Revenue has been clear on this point: no PFN means no R&D tax credit claim.

Additional consequences can include:

• Disrupted cash flow planning if you were counting on R&D credit refunds
• Potential scrutiny of future claims, as Revenue may question your understanding of the scheme requirements
• Internal compliance issues if the missed credit affects your business planning or stakeholder commitments

But it doesn't have to spell the end of your R&D credit journey. The key is implementing robust processes to ensure you never miss the deadline again.

Practical Tips for Businesses

Smart businesses build PFN requirements into their annual planning cycle rather than treating them as last-minute administrative tasks.

Create a systematic approach:

1. Calendar the deadlines – Mark your accounting period end dates and set reminders well in advance
2. Assign responsibility – Designate specific team members to handle PFN submissions and create backup coverage
3. Integrate with R&D planning – Consider PFN requirements when planning R&D projects and budgets
4. Document everything – Keep detailed records of all PFN submissions, including proof of delivery

Many businesses find that working with experienced R&D tax advisers eliminates the risk of missed deadlines entirely. Professional advisers can integrate PFN management into comprehensive R&D tax planning, ensuring you get your credits while maintaining full compliance.

Good record-keeping serves multiple purposes: it supports your PFN submissions, strengthens your actual claims, and demonstrates good governance to Revenue.

Looking Ahead: Making PFN Work for Your Business

Remember: missing a PFN deadline means losing your entire R&D tax credit for that period, regardless of how much qualifying work you've undertaken. But with proper planning and systematic approaches, you can ensure this never happens to your business.

If you're planning R&D activities or have questions about PFN requirements for your specific circumstances, don't leave it to chance. Professional guidance can help you navigate these requirements confidently while maximising your overall R&D tax position.

Need help with pre-filing notifications or R&D tax credit planning? Myriad’s expert team specialises in helping Irish businesses claim R&D tax relief while maintaining full compliance with Revenue requirements. Contact us to discuss your specific situation and ensure you never miss a critical deadline.