Evidence shows that investment in research and development is a critical factor driving innovation and growth. This is true both on a macro level for governments and for individual businesses. In an era when the world is becoming more research-intensive, Grant Thornton’s latest International Business Report (IBR) shows that global net R&D investment expectations rose to 36% in the first half of 2019. This was up from 31% in the second half of 2018 and is the highest level on record.
This is part of a longer-term trend. For example, EU member states collectively spent €320 billion on R&D in 2017, which represents 2.07% of GDP. In 2007, that R&D intensity was just 1.77%[i]. Even these impressive numbers are dwarfed by other regions and countries; R&D intensity in South Korea was 4.22% in 2015 and in Japan 3.28% in the same year. The EU, through its Horizon 2020 programme, aims to increase its R&D intensity to 3% in 2020.
Governments worldwide use a variety of tools to stimulate R&D in order to make their homegrown businesses more successful, as well as to attract foreign direct investment and international talent where specialist skills are scarce. Between 2000-13, government incentives accounted for nearly 70% of all R&D undertaken in OECD countries[i]
In recent years there has been an increase in government activity in several regions, with benefits often being seen rapidly. According to IBR data, in Singapore net R&D investment expectations jumped to 17%, the highest since Q2 2017, following the introduction of a new R&D incentive regime in which every dollar of qualifying expenditure on R&D received enhanced tax deductions of 250%.
In Poland, which increased its tax deduction on R&D in 2018, net investment expectations were 44% in the first half of 2019, the highest on record. Italy and Greece also saw changes to patent box and innovation incentives and witnessed robust hikes in net R&D investment expectations. In Italy it rose to 44%, up from 30% in the second half of 2018, while in Greece it leapt to 48% from 16%.
With reference to the Italian situation, Sergio Montedoro, partner at Bernoni Grant Thornton, declared: “According to the latest IBR, despite a general decrease in optimism, 45% of global businesses expect to increase their R&D spending in the next 12 months. Italy registered a similar trend, as 50% of businesses expect to increase their investment in R&D activities.
A perfect example of this trend is represented by Innovative Small and Medium Enterprises (SMEs), a type of business that is characteristic of the Italian entrepreneurial environment and particularly focused on innovation and research. Innovative SMEs are officially recognized and regulated by the Italian government and one of the requirements to be classified as innovative SME is investment in R&D.
In terms of incentives, the Italian government provides for Innovative SMEs the possibility to benefit from various tax reliefs, including: R&D tax credit, #ItalyFrontiers platform, flexible corporate regulation, facilitated loss coverage, exceptions in the regulation on shell companies, stock option & work for equity, equity crowdfunding, and several other tax incentives dedicated to innovative SMEs.
As many studies are demonstrating, innovation and research are key to turn the complex global economic scenario in a growth and development opportunity”.
Some jurisdictions don’t offer tax incentives for R&D - for example, Germany, Finland and Mexico only offer direct government funding through grants. However, the recent trend has been a shift away from direct funding towards use of tax relief. Indeed, even the German government is proposing a new R&D tax credit to come into force in 2020 that would allow businesses to claim a tax credit worth 25% of the wages and salaries paid to research staff[ii].
It’s natural that countries differ in the way they approach grants, but some businesses find there isn’t always consistency within one country as to the availability of funds. What is available one year may not be offered the following year and it can be a challenge for businesses to find the right grants that apply to them.
For the most part, R&D tax relief programmes point investment where the market needs, rather than policymakers wish. Every country has its own definition of qualifying R&D and its own approach to policing tax relief, but, generally, they are less prescriptive than grants.
The UK increased its support for R&D relief significantly in 2013, when the government introduced a repayable tax credit scheme for larger companies, where one had previously only existed for smaller enterprises.
But certainty in the system can be as valuable as the benefit itself. At one extreme, the R&D tax credit in the US was only made permanent in 2015, a full 35 years after its creation. Businesses could not be sure it would be there from one year to the next. Now, at last, they are free to take the R&D tax credit into account when forecasting for the future. Meanwhile, in Australia, there is a debate about tightening up the regime by capping the amount of R&D tax credits businesses can get.
Then there is that category of business less familiar with R&D and less certain of the regulators’ interpretation of what qualifies.
In South Africa, the government introduced an R&D tax incentive which according to the Department of Science and Technology has supported about R49 billion in R&D expenditure since 2006, a modest amount compared to the country’s GDP over the same period[iii].
Often referred to as ‘patent box’ or ‘innovation box’, income-based tax incentives provide relief on the income generated from the R&D, such as income from licensing or asset disposal attributable to R&D and patents. Patent box regimes are relatively widespread, with most implemented in the last two decades.
However, OECD countries have agreed on the Modified Nexus Approach for IP regimes as part of the organisation’s Base Erosion and Profit Shifting (BEPS) Action Plan. The agreement requires regimes to have a clear link between R&D expenditures, IP assets and IP income in that jurisdiction. As a result, previously non-compliant countries have either closed or amended their patent box regimes in the past few years.
Switzerland is among the latest jurisdictions to introduce a new patent box, which comes into effect in 2020, providing a maximum tax base reduction of 90% on income from patents and similar rights developed in Switzerland[iv].
Some businesses are not always aware of what they are entitled to in this area. The Netherlands, for example, has a broad innovation box regime with qualifying assets including patents, software and less novel or obvious assets applied to smaller businesses.
According to the OECD, there is less evidence around how effective patent boxes are in stimulating further R&D activity. These income-based incentives provide ‘follow on’ savings from R&D tax reliefs and grants, encouraging businesses to hold and exploit the IP developed in the jurisdiction which invested in the R&D activities. However, whether and to what extent these incentives directly stimulate further R&D is unclear.
[i] OECD, Sep 2016
[ii] Tax Foundation, April 2019
[iii] https://www.dst.gov.za/rdtax/index.php/reports/annual-reports/27-2017-18-r-d-tax-incentive-programme-annual-report/file
[iv] Tax foundation, June 2019