Eligibility, calculation, technical proof: every euro of CIR must be defensible
***
CIR tax audit: an increasing probability to anticipate
The CIR-related controls are increasingly frequent. They may include in-depth technical expertise, in particular an assessment of the scientific nature of the work by an expert appointed by MESRI (the French Ministry of Higher Education, Research and Innovation). To avoid any unpleasant surprises, it's best to anticipate these audits by structuring your technical file and receipt.
Justifying every euro of CIR: the two essential components
Your company must be prepared to justify every euro declared under the CIR. And this on two essential fronts:
- Eligibility of R&D and/or innovation work
You need to demonstrate that your projects involve scientific and technical research or innovation that meets the precise criteria of the various schemes.
- Calculating your tax credits
You'll need to be able to justify all declared expenses: remuneration of valued personnel, subcontracting, depreciation, etc.
Preparing a complete CIR file: administrative and technical
You don't have to prepare this file in a hurry, but rather build it upstream, ideally as soon as you start working on your CIR return.
Administrative and financial file: documents required
This file is used to demonstrate the reality and traceability of eligible expenses. It includes :
- CVs and diplomas of personnel involved;
- Time sheets for each project/person (remember to use a time recorder). time tracking tool for your teams) ;
- Payroll and remuneration elements ;
- Equipment depreciation schedules ;
- Invoices for internal or external subcontracting (approved or unapproved subcontractors); contracts, specifications, etc.
- Technology watch invoices ;
- ...
HR and subcontracting issues
Our advice
If you haven't already done so, don't hesitate to contact your HR department. Diplomas must be systematically requested. In the event of the departure of a valued employee, it is imperative to check that the diploma is in the company's possession before the employee leaves.
It's also a good time to check for the last time that you are in possession of your subcontractors' CIR approvals issued by the French Ministry of Research, and to ask them for any certificates that are missing or not kept.
Technical or scientific file: demonstrating the R&D or innovation process
Here, the aim is to demonstrate that the work declared is indeed research or innovation within the meaning of the CIR, CICo or CII:
- Description of the general context of the declared operation; or the state of the market?
- Description of the scientific or technical problem identified and justification of the need to undertake an R&D operation to resolve it; Description of the objectives and performance to be achieved;
- Detailed description of scientific approach and work carried out; Description of innovative work carried out;
- Description of the results of the declared operation and the scientific and/or technical contribution to the acquisition of new knowledge in R&D with regard to the state of the art;
- Description of research and/or innovation indicators.
Resources, equipment, subcontractors: leave no stone unturned
Don't forget :
- Description of human resources: qualifications and highest diploma; function and direct contribution of each staff member to the acquisition of new knowledge, justification of the adequacy of declared times in relation to the work described.
- Material resources used: equipment, prototypes ;
- Partnerships and subcontracting: specify each party's contribution.
Capitalizing on your knowledge: a strategic challenge for the years ahead
The tax authorities can check your tax credit up to three years after declaration. Now is the ideal time to evaluate your knowledge capitalization system.
What happens if a project manager leaves the company in the meantime? Who, internally, will be able to explain to a tax inspector or an expert from the Ministry the work carried out several years ago, and demonstrate that it does indeed meet the criteria for the CIR, CII or CIF? CICo ?
Anticipating these questions means giving yourself the means to secure your declarations. Structure your processes, document your projects, and always stay one step ahead.