FKINP An Australian company should own the evidence and eligibility decisions, use a consultant where needed for activity analysis and registration, and have its accountant handle expenditure treatment and the ATO tax-return claim.[1][2][8]
Activity registration and the ATO claim are separate
The R&DTI has two stages: register the company’s activities through the secure R&DTI customer portal, then use the registration number to claim the tax offset or refund through the ATO process.[1][7]
Registration is not approval of eligibility. The program is self-assessed, so the company remains responsible for determining whether its activities and expenditure qualify.[1] A registration letter, refund or tax adjustment does not show that the government has accepted eligibility.[3]
The activity-registration deadline is 10 months after the end of the company’s income year unless an extension has been granted.[1]
Divide responsibility across the claim lifecycle
Advisers can prepare the work, but responsibility for eligibility and substantiation remains with the company.[1][2]
- Evidence capture — company: appoint an internal owner, keep technical and financial records accessible, and have project teams capture evidence as work occurs.[2]
- Eligibility analysis — consultant prepares, company approves: the consultant can analyse activities and interview technical personnel, but the company should review the resulting eligibility position.[1][8]
- Application drafting — consultant: prepare activity narratives and connect the technical work to the relevant financial records within the agreed scope.[8]
- Portal review and submission — agreed authorised party: require company review before submission. Portal access requires authorisation, but the official guidance does not confirm whether consultant access permits final submission without separate company approval.[1]
- Cost calculation — accountant, with consultant input: the accountant should lead expenditure treatment, tax adjustments and reconciliation, while the consultant explains how costs relate to registered activities.[7][8]
- Tax-return lodgment — accountant: the accountant prepares and lodges the ATO claim, subject to the company’s approval process.[7][8]
- File retention — company: keep the complete technical and financial substantiation file because responsibility does not transfer to an adviser.[2]
Company approval points are governance controls. The official application guidance does not prescribe a particular director signatory or approval wording beyond the declaration about contemporaneous records.[1]
Build the evidence file before drafting
The applicant must declare that records were kept while the activities occurred and can be produced if requested.[1] The ATO says documentation should capture each activity’s process as it develops; retrospective records will generally be inadequate on their own without contemporaneous evidence.[2]
Organise the file into linked technical and financial evidence, and centralise it so the claim does not depend on records held by one employee.[3]
- Technical evidence: research plans, emails, meeting minutes, analyses, test results, prototypes, screenshots, code repositories and software versions.[3]
- Financial evidence: timesheets, contracts, schedules, invoices and documented methods for apportioning costs between eligible R&D and other work.[2][3]
Draft the application from this evidence. Core and supporting activities have different requirements and must not be combined. Core activities may be grouped only when they address the same technical uncertainty.[1]
Authorise the consultant without losing oversight
Official guidance requires customer-portal authorisation and distinguishes between the company’s principal authority, company staff, an individual tax agent or R&D consultant, and a tax agency or consultancy.[1]
Define the consultant’s scope in writing: information collection, drafting, portal data entry, submission support or another agreed role. Grant access suited to that role and retain an internal principal authority who can inspect the application and records. The company remains responsible for eligibility even when a consultant prepares or submits the application.[1]
The cited official guidance does not explain whether every consultant authorisation permits independent final submission or how access is revoked, so confirm the portal permissions and revocation process before granting access.[1]
As a company control rather than a prescribed portal procedure, approve the final activity list, technical narratives, declarations and attachments before submission, and record who completed the review.
Give the accountant a claim-ready handoff
For the ATO claim, give the accountant a version-controlled package connecting each registered activity to the expenditure claimed. Specialist guidance says R&DTI expenditure treatment differs from ordinary company-tax deductions and that a consultant should work alongside, not replace, the accountant.[7][8]
- Technical file: final activity names and classifications, project dates, technical uncertainties, systematic progression, test records, links between supporting and core activities, and an index of source records.[1][3]
- Financial file: general-ledger extracts, payroll and time records, contractor invoices and contracts, cost-to-activity mapping, excluded amounts, adjustments and documented apportionment methods.[3] The ATO requires reasonable methods for distinguishing eligible R&D expenditure from expenditure on other activities.[2]
- Claim-control file: the submitted application, registration correspondence, working assumptions, unresolved eligibility questions and a reconciliation between the registration narrative and tax calculation.
The accountant should also assess the accounting treatment. Pitcher Partners describes refundable offsets as commonly considered under AASB 120 and non-refundable offsets under AASB 112, with further issues under AASB 138 where development costs are capitalised.[5]
Keep the authoritative master file under company control. Advisers may retain working copies, but substantiation responsibility remains with the taxpayer.[2]
Compare four R&D tax service models
Compare the models on claim complexity, existing documentation and available internal time. The provider descriptions do not establish a universal staffing threshold or complexity limit.[4][8]
Internal or DIY
- Complexity: Bulletpoint presents DIY work as suited to relatively straightforward activities.[8]
- Documentation quality: It is more workable where good technical and financial records already exist.[8]
- Internal capacity: Staff need enough time to coordinate the registration, cost records and accountant handoff.[8]
Accountant-led
- Complexity: Bulletpoint says an accountant may coordinate a relatively simple claim, while multiple projects, larger expenditure or difficult eligibility questions may warrant specialist input.[8]
- Documentation quality: It identifies incomplete records as a reason to add a specialist rather than rely on the accountant to reconstruct the technical case.[8]
- Internal capacity: The company must still oversee evidence and substantiation because responsibility remains with the taxpayer.[2]
Hands-on consultant
- Complexity: Bulletpoint positions this model for complex eligibility questions, several technical teams or larger R&D expenditure.[8]
- Documentation quality: Its described service includes technical-team interviews, narrative drafting, financial review and preparation for lodgment.[8]
- Internal capacity: Company personnel remain involved in evidence and eligibility decisions, while the consultant works alongside the accountant.[1][8]
Platform-assisted hybrid
- Complexity: ClaimKit identifies software teams using GitHub, Jira, Linear, Notion and Xero as potential users of this model.[4]
- Documentation quality: Its described workflow combines platform-led evidence gathering and drafting with human expert review.[4]
- Internal capacity: Founder and engineering input is still required, so the platform does not remove internal participation.[4]
What to confirm with each provider
Percentage or success fees, fixed fees, staged fees and hybrid or platform pricing are identified service models. ClaimKit says success fees may cost more for straightforward, well-documented claims, while fixed fees may suit predictable claims with internal finance capacity; these are provider assessments rather than independently tested findings.[4][8]
Ask each provider to quote against the same checklist:
- Scope and deliverables: technical interviews, financial reconciliation, amendments and access to workpapers.
- Responsibility: exclusions, portal work, company approval points and coordination with the accountant.
- Post-lodgment support: responses to information requests, reviews and audits, including hour limits.
- Commercial terms: fee basis, minimum charges, payment timing, engagement length, cancellation, refunds and liability allocation.
The cited pages for Fullstack, ClaimKit and Swanson Reed [3][4][6], and for TechAbstract, Bulletpoint and BDO [7][8][9], do not state all actual fees, percentages, minimum charges, cancellation or refund terms, liability allocation, or included review and audit hours.
Choose the model and document the handoff
DIY or accountant-led support is more suited to relatively simple activities, organised records and a company with enough internal time to coordinate the work.[8] Hands-on or platform-assisted support may be more suitable where eligibility is complex, evidence is fragmented, several teams contribute or technical work is poorly linked to costs.[4][8]
Work backwards from the registration deadline of 10 months after the income year ends. Limited detail, potentially excluded activities or other identified eligibility risks can lengthen processing.[1] Record the internal file owner, the consultant’s portal role, company approval points and the date the completed package must reach the accountant.
References
- Apply for the R&D Tax Incentive | business.gov.au (business.gov.au)
- Helping you get R&D claims right | Australian Taxation Office (ato.gov.au)
- R&D Tax: Documenting Best Practice Claims (fullstack.com.au)
- Research and Development Tax Consultant: Your 2026 Guide | ClaimKit (claimkit.co, 2026)
- R&D Tax Incentives: Getting the accounting right – Pitcher Partners (pitcher.com.au)
- R&D Case Law: Substantiating an Experiment | Swanson Reed (swansonreed.com.au)
- R&D Tax Incentive FAQ – frequently asked questions (techabstract.com)
- R&D Tax Consultant Australia – R&D Tax Incentive Advice & Claim Support (bulletpoint.com.au)
- R&D tax incentive services – BDO (bdo.com.au)
