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Contact usIreland’s R&D tax credit hits 35% from 2026. See how it compares with the UK, France, Germany, the Netherlands and Spain on rates and cash.
Ireland has long positioned itself as one of the world’s most attractive destinations for businesses, and its R&D tax credit system is a significant part of that story. But how does Ireland's offering really stack up against its EU neighbours? Is it worth considering when setting up your next R&D project?
In this article, we compare Ireland's R&D tax credit regime with those in key EU member states (and the UK), looking at credit rates, generosity, cash flow provisions, and strategic positioning.
Ireland’s R&D tax credit is administered by Revenue and provides a credit against corporation tax for eligible R&D expenditure. If you have qualifying R&D activity, it’s a support you don’t want to miss.
Companies have historically claimed a tax credit of 30% on qualifying R&D costs. The good news is that this rate has risen from 30% to 35% for accounting periods beginning on or after 1 January 2026. You can elect to claim the credit as a reduction in corporation tax due or in cash, typically paid in three annual instalments.
Eligible expenditure includes staff costs, subcontracting expenses, consumables, software, and, in some cases, capital expenditure. Alongside the rate increase, Budget 2026 also raised the first-year payment threshold to €87,500. In practice, this means smaller claims now receive more of their credit up front, which is welcome news for SMEs and start-ups.
The table below summarises the headline features of R&D tax regimes in Ireland, selected EU countries and the UK.
|
Country |
Credit/Relief Rate |
Refundable in cash? |
Key Notes |
|
Ireland |
30–35% credit |
Yes (3 instalments) |
Rate rises to 35% from 1 Jan 2026. Broad cost base. |
|
UK |
20% taxable credit (≈15–16% net); 27% net for R&D intensive SMEs |
Yes (subject to PAYE cap) |
Merged scheme mandatory from April 2024. Cash refund only after Corporation Tax, PAYE and other liabilities are settled. |
|
France |
30% credit up to €100m; 5% above |
Yes |
Generous on paper, but cash refunds can take time to process. |
|
Netherlands |
36–50% WBSO wage subsidy |
Yes (payroll tax reduction) |
Applies to wage tax only. Lower rate for large companies above threshold. |
|
Belgium |
Up to 40% investment deduction + 80% payroll withholding exemption |
Partial |
Separate 85% innovation income deduction also available on qualifying IP income. |
|
Germany |
25% credit (35% for SMEs) |
Yes |
Capped at €10m qualifying R&D per year (max €2.5m / €3.5m benefit). Project certification required. |
|
Spain |
25%, increases to 42% where R&D spend is growing |
Partial |
Among the most generous, but administration is complex. |
A number of factors set Ireland apart from its EU and international peers, even beyond the headline credit rate.
Ireland’s R&D tax credit applies to a wide range of qualifying costs. These include staff wages, materials used in R&D, plant and machinery in some cases, and payments to third-party researchers and universities.
This broad base means more of your genuine innovation spend qualifies. By contrast, the Netherlands’ WBSO is restricted to wage costs and applied against payroll tax, while France’s scheme focuses heavily on researcher salaries and approved subcontracting.
Ireland’s R&D tax credit is fully payable if you elect to receive it in cash. Companies can receive a cash refund in three annual instalments, regardless of their tax position. Compare this to the UK, where the cash element of the merged scheme can only be paid once your corporation tax and PAYE liabilities are settled.
For companies with smaller claims in Ireland, you could receive your full tax credit in the first year, as long as the credit is worth less than the first-year payment threshold (currently €75,000, increasing to €87,500 from 2026).
Germany and the Netherlands both require companies to have R&D projects pre-approved or certified before a claim can be paid. The tax credit in Germany, for example, requires certification before the tax authority will release funds.
Ireland’s system has no pre-approval requirement. You undertake the work, keep strong records, and claim at the end of your accounting period. That’s a material advantage for fast-moving R&D teams who can’t wait months for paperwork before starting a project.
That said, Revenue audits are real and increasingly common. “No pre-approval” doesn’t mean “no scrutiny”; it means the scrutiny may come after the claim, not before. Strong documentation remains essential.
Spain’s R&D incentives, while generous on paper at up to 42%, are known for administrative complexity that makes it difficult to access the full benefit in practice. France’s tax credit has a clearer structure, but cash refunds can take several years to arrive.
Ireland’s claim process sits between these extremes. It’s accessible and, for most SMEs, can be completed in a few weeks of focused work with the right records in place.
The OECD (the Organisation for Economic Co-operation and Development) is an international body of 38 countries that designs policies for economic development. One of its frameworks, Pillar II, ensures that large multinational enterprises (MNEs) with annual revenues over €750m pay a minimum global tax of 15% on profits.
Under Pillar II’s Qualified Refundable Tax Credit (QRTC) rules, only fully refundable credits are excluded from the effective tax rate calculation. Non-qualifying credits can have their value partially offset for MNEs in scope.
Ireland’s R&D tax credit, being fully refundable, qualifies as a QRTC under Pillar II. That means it doesn’t reduce a company’s effective tax rate in the same way that non-refundable credits do. This is a significant advantage compared to regimes such as Belgium’s, where elements of the relief may not meet the QRTC test.
Budget 2026’s increase to 35% was partly designed with this in mind. It ensures the credit remains meaningful for all companies, including MNEs inside the Pillar II net.
The R&D tax credit doesn’t stand alone in Ireland. When viewed as part of the wider innovation support environment, the case for Ireland becomes stronger still. That ecosystem includes:
While France’s tax credit offers a comparable headline rate, it comes with more complex administration and a narrower scope of eligible costs. Germany’s tax credit remains capped, newer, and requires additional upfront admin. Ireland’s regime has been in place since 2004, has been progressively enhanced, and benefits from a government that has consistently signalled its commitment to R&D as a policy priority.
Whether you’re benchmarking Ireland against an alternative European HQ or reviewing an existing claim in light of the new 35% rate, the comparison is worth doing properly. Contact our team and we’ll walk you through how the numbers work for your business.
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Please contact us to discuss how working with Myriad can maximise and secure R&D funding opportunities for your business.
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