Many companies misunderstand the additional deduction for R&D expenses as simply ”filling out a form and claiming an additional deduction,” only to have the entire amount adjusted upward during subsequent audits, resulting in back taxes and late payment penalties that can easily run into the millions. The problem almost never lies in the percentage rate, but rather inChain of EvidenceThe

First, figure out which bracket applies to you.

According to industry sources, the additional deduction rate for R&D expenses for technology-based small and medium-sized enterprises and manufacturing companies is 100%; there are rumors that certain industries, such as integrated circuits, have higher rates, butFor specific application rates and requirements regarding the management of the list, please refer to the latest announcements issued by the Ministry of Finance and the State Taxation Administration., Do not file your return based on forms circulating online.

There are two points that require special attention:

First, Additional DeductionsIt's not just high-tech companies that are eligible for this benefit. As long as the business is not in an industry on the negative list (such as tobacco manufacturing, lodging and food services, wholesale and retail, real estate, etc.) and its R&D activities meet the definition, it is eligible.

Second, companies must make a ”substantive determination” regarding their R&D activities. According to industry sources, the 2026 regulations place greater emphasis on companies’ need to substantively engage in R&D activities; relying solely on a set of auxiliary accounts maintained merely to pass inspections now carries a high level of risk.

Seven Categories of Records That Must Be Retained for Inspection

1. R&D Project Proposal: Includes project objectives, technical approach, budget, timeline, and project team members
2. List of R&D Personnel and Time Logs: Can be linked to specific projects
3. R&D Expense Subsidiary Ledger: Grouped by project, with consistent reconciliations with the accounting suite
4. Cost Allocation Table: Basis for Allocating Costs for Shared Equipment, Shared Personnel, and Shared Facilities
5. Research and Development Results Report: Milestones, Test Records, Prototypes/Software Versions
6. Contract for Commissioned Research and Development and Certificate of Ownership of Research Results(if any)
7. Government Project Approval or Certification Documents(If available, this may serve as supporting evidence)

Keeping records on file for future reference does not mean ”storing them in a drawer.” When tax authorities request these records, they must be able to corroborate one another and be chronologically consistent.

The Three Most Common Reasons for Rejection

Scenario 1: Discrepancy Between Headcount and Expenses. A company reports the salaries of R&D personnel, but in the individual income tax system, these employees” job titles are listed as ”sales” or ”administration”; or the social insurance contributions for R&D personnel are paid by another affiliated company. This is the number one red flag identified by big data comparisons.

Scenario 2: Inverted Temporal Logic. If the project approval date is later than the date the expenses were incurred, or if the R&D results report date precedes the project approval date, such fundamental flaws, once discovered, will result in the entire batch of expenses being deemed invalid R&D expenses.

Scenario 3: Blurring the Lines Between Production and R&D. Do not include production-stage tooling, molds, and prototype materials in R&D expenses, nor should you include sales personnel travel expenses or routine quality inspection costs in R&D expenditures. There must be a clear distinction between R&D expenses and production costs, and verifiable allocation methods must be in place for shared costs.

Differences from the High-Tech Enterprise Certification Process

The additional deduction system and the high-tech enterprise certification system are two separate frameworks, but they share a significant amount of underlying documentation. A common issue in practice is that companies prepare one set of R&D documentation based on the 15% tax rate for high-tech enterprise certification, but then create a separate set for the additional deduction, resulting in conflicting data between the two sets.

It is recommended to standardize the R&D management system, with a single set of project records supporting high-tech enterprise status, additional tax deductions, and any potential future special audits.

A quick reminder

Tax deductions are subject to the principle of ”self-assessment, self-reporting, and retention for future reference”; however, “retention for future reference” does not mean exemption from audit. Tax authorities have the right to conduct audits during subsequent administrative reviews. If a taxpayer is found to be ineligible, they must pay the back taxes and a daily late payment penalty of 0.05 percent.

Specific policies and reporting guidelines are subject to the announcements issued by the State Taxation Administration. Qicaiying can assist companies in setting up auxiliary ledgers for R&D expenses, strengthening the evidence chain for project initiation and man-hours, and conducting specialized reviews for additional tax deductions.