23 Jul 2026
etailment features innoscripta COO Sebastian Schwertlein on research allowance for retail innovation
etailment shares insights from innoscripta COO Sebastian Schwertlein on how retail companies can benefit from Germany's research allowance for innovative development projects. The article outlines the enhanced funding opportunities introduced in 2026 and highlights the importance of identifying eligible R&D projects, supported by structured project documentation, with examples from AI, automation, omnichannel systems and digital logistics.
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17 Aug 2026
IP Box in France: Recent court rulings
What does the IP Box involve?The "IP Box" is a tax mechanism provided for in Article 238 of the General Tax Code (CGI) that allows a reduced tax rate of 10% to be applied to income derived from the exploitation of certain intellectual property rights, particularly in the context of licensing agreements.In the case of software, the company must demonstrate that the asset is protected by copyright and calculate the eligible income. The option is exercised on a per-fiscal-year basis (whether to opt in or maintain the election) and is formalised by filing a specific schedule.Judgment of the Administrative Court of Cergy-Pontoise, 5th Chamber, 29 January 2026, No. 2308638In this case, the taxpayer—a company specialising in the development of telecommunications products and services—filed amended tax returns serving as formal claims to benefit from the special reduced tax rate of 10% provided for under Article 238 (the so-called "IP Box" regime). The tax authorities rejected the request on the grounds that the option had to be exercised in the initial tax return and could not be claimed retroactively via an amendment.The judges held that Article 238 of the General Tax Code (CGI) specifies no deadline for electing this regime and that no law requires the submission of the supporting schedule at the same time as the initial return. Consequently, the court upheld the right to make such a claim, provided it was filed within the general time limit set out in Article R. 196-1 of the Book of Tax Procedures. Noting that the company had provided sufficiently detailed documentation and that the tax authorities did not dispute the calculation of net income, the court authorised the application of the reduced rate and granted the discharge of the tax liability.This decision confirms earlier rulings handed down on this matter during 2025.Key takeawayRetroactive option: The IP Box regime may generally be elected retroactively by filing an amended tax return or a tax claim, provided that the statutory deadlines under Article R. 196-1 of the French Tax Procedure Code are met.As a general rule, the amendment must be submitted no later than 31 December of the second year following the year in which the relevant corporate income tax was paid. The decisive date is therefore not only the financial year concerned, but also the year of the tax payment.For example, if the corporate income tax for the 2023 financial year was paid in 2024, the deadline for filing the amendment would generally be 31 December 2026.Judgment of the Administrative Court of Poitiers, 1st Chamber, 17 March 2026, No. 2301859The publisher of the accounting software Macompta.fr simultaneously applied for the IP Box regime and the innovation tax credit (CII) for the 2020 and 2021 financial years. The tax authorities rejected both claims. The courts examined each claim separately and ruled in favour of MACOMPTA regarding the IP Box aspect.Below are the key takeaways from the ruling by the Administrative Court of Poitiers concerning the IP Box regime.Key takeawaysProof of prior existence: Depositing source code with a trusted third party (such as the APP, a judicial officer, or a certification authority) serves as useful evidence to demonstrate prior existence and ownership of rights. While such a deposit is not sufficient on its own to establish the software's originality, it helps substantiate the claim that the asset is an original creation of the company and qualifies for copyright protection;Revenue allocation: Where subscription revenue comprises both a software licensing component and service elements (hosting, maintenance, support, etc.), an allocation method based on costs incurred during the financial year is acceptable. This methodology involves distinguishing between costs associated with non-eligible services and costs directly linked to the development and operation of the eligible software. The resulting ratio allows revenue to be apportioned between the share eligible for the IP Box regime and the share corresponding to non-eligible services;Option to elect by asset family: If multiple intangible assets (software modules) generate inseparable revenue (e.g., a global subscription) and the specific contribution of each cannot be reliably determined, the company may elect to apply the IP Box regime at the level of an asset family (e.g., a software suite). Eligible income is then calculated on an aggregate basis for the grouped assets, provided the company can justify their complementarity and the impossibility of meaningful individual tracking.
13 Aug 2026
Maximizing Qualified Research Expenses (QREs) for the US R&D tax credit: A strategic framework for CFOs and tax leaders
In an era defined by rapid innovation and technological disruption, the Research and Development Tax Credit under Internal Revenue Code (IRC) Section 41 is one of the most powerful monetary tools available to US enterprises. For high-growth firms, this opportunity can translate into financial support in terms of immediate tax savings and increased cash flow.Despite this direct opportunity, many companies pursuing innovation fail to capture the full economic value of their novel initiatives. The main reason for not leveraging this federal-level opportunity is not a lack of eligible innovative activity, but rather a failure to establish a systematic operational framework to recognize, document, and substantiate Qualified Research Expenses (QREs). To maximize the credit, tax leaders must adapt their perspective from viewing the R&D credit as a year-end compliance task to considering it as a continuous operational discipline.What are QREs?To optimize a claim, it is crucial to be familiar with the statutory IRS definitions of the three primary costs. The IRS provides a meticulous roadmap for which expenditures qualify as QREs.1. Qualified wagesThe category of qualified wages constitutes a significant portion of any R&D claim, and it includes the “Box 1” taxable wages paid to employees for qualified services. This consists of personnel in direct supervision and direct support roles, along with the engineers and scientists performing R&D.2. Qualified suppliesThese are tangible, non-depreciable assets used and consumed during the R&D process. For example, chemicals for lab testing and materials used for building prototypes specifically for qualified research activities.3. Contract research expenses65% of the total costs incurred for hiring a third-party research firm to perform the R&D project on the company’s behalf are eligible for the credit claim.Why valuable QREs go unrecognizedDespite having eligible activities, many companies submit insufficient R&D claims. The loss of value usually arises from three core elements:Fragmented data ecosystemsIn many companies conducting R&D, the data needed for a well-substantiated claim is scattered across different systems. For example, technical activities recorded within Jira or Azure DevOps, payroll information in ADP, and operational or supply costs recorded in the general ledger. Without a unified and interconnected system that offers holistic documentation, these data points become subject to guesswork. An intuitive platform such as innoscripta’s Clusterix bridges the gaps in project documentation, ensuring zero omission of information and audit readiness.Risk of retroactive reconstructionThe IRS has signalled a remarkable change toward requiring contemporaneous documentation. Hence, depending on year-end interviews or retrospective surveys to substantiate a significant amount of credits is a high-risk strategy. If documentation was not created simultaneously at the time of the research work, the IRS may consider the claim ‘unsubstantiated.’Misclassification of activitiesCertain companies often view R&D as involving only successful outcomes or cutting-edge inventions. However, Section 41 provides for a broader inclusion. Iterative development, failed experiments, and process improvements intended to eliminate technical uncertainty are considered valid activities upon which the R&D credit claim could be based. Many companies leave significant QREs unclaimed, as they never document the ‘process of experimentation.’Five strategies to maximize QRE capture1. Implementing activity level trackingTo maximize wage QREs, companies should move away from overall percentage-based time estimates. By implementing task-based time tracking for project work, tax leaders can defend every hour mentioned in the claim with granular data. This includes capturing ‘direct support’, for example, a lab technician cleaning the equipment used for qualified research, and ‘direct supervision’, for example, a CTO reviewing technical roadblocks.2. Mapping expenses against business componentsThe IRS demands that every dollar claimed be tied to a specific business component, which may be a product, process, or software. When a claim merely lists the total sum of wages without breaking them down into components, it is considered a negative indicator to auditors. A company must demonstrate a clear link between the expense and the specific task for which it was incurred.3. Including supply and contractor costsFor a company, the ability not to overlook hidden R&D costs brings a lot of value to their claim. Elements such as testing supplies, and prototype materials are examples of this. In the case of contract research, the company needs to ensure that the official contract specifically states that they retain substantial rights and bear the economic risk of the research, which are two critical factors for eligibility.4. Integrating technical, financial, and substantiating recordsMaximizing QREs requires a three-way match between the technical narrative, the financial records, and the substantiating evidence. In other words, the alignment between what was done, what was spent, and the proof that it happened is a crucial factor in a successful claim. The methods to ensure this include aligning the ERP and project management software, where these three pillars are accurately synchronized.Examples of this include payroll information tied to research activities, financial records tied to respective projects, and engineering work tied to experimentation.5. Following the consistency ruleUnder Section 41, the R&D credit is incremental, comparing current spending against a base period. It requires that QRE calculations remain consistent across years, and base-period comparisons must align with the current methodology. If there are new QREs this year that were previously uncaptured, the IRS would require the company to update the base period for consistency. If a company skips updating the base period, during an audit, the IRS will recalculate and inflate the base period, which will significantly shrink the claim or eliminate it entirely.ConclusionMaximizing QREs is not just about discovering more expenses; rather, it is about building a defensible system that captures the R&D project comprehensively. From the IRS’s perspective, if it is not contemporaneously documented, it did not happen. The transformation from retrospective estimation to real-time infrastructure is the foundational step a CFO or tax leader can adopt to enhance their R&D tax benefits.When companies realize that the R&D tax credit is a continuous opportunity, they transform their manual spreadsheets and year-end information gathering into automated and systematic documentation that records the project contemporaneously. As a result, they achieve maximum capture of QREs and audit readiness.
