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Home›Specialisms›Technology & Software
💻 Specialism · Technology & Software

Tax for technology & software businesses.

Most accountants serving tech are accountants first and tax advisers second. We’re the other way round — Chartered Tax Advisers (CTA) and Fellow ACCA, with an active Head of Tax — Europe role at a major digital infrastructure operator. R&D claims, EMI schemes, international structuring and growth-stage tax planning, handled in-house.

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Technology tax at a glance

20%
RDEC credit on qualifying R&D
27%
ERIS rate for R&D-intensive SMEs
£1m
BADR lifetime allowance for founders
£60k
Annual pension allowance
CTA-qualified tax-led advice
R&D claims with technical narratives
EMI schemes, valuations & documentation
UK-US-EU structuring expertise

Why technology tax needs more than a generalist accountant

Most software and technology businesses are served by accountants whose technical depth ends at year-end statutory accounts and an outsourced R&D referral. That works while the business is small and the tax position is simple. It stops working the moment the business has employees worth giving equity to, customers in multiple jurisdictions, R&D activity worth claiming for, or investors who care about how the cap table is structured.

The recent direction of travel makes this gap wider. The R&D regime has been overhauled twice in three years (the merged RDEC scheme from April 2024, the ERIS regime for R&D-intensive SMEs, and the new disclosure requirements that have caused HMRC reject rates to rise sharply). EMI schemes remain the single most tax-efficient way to give equity to UK employees but the rules around exercise, valuation and qualifying conditions trip up companies that don’t structure them carefully. Dividend tax rates rose again in April 2026 to 10.75% basic / 35.75% higher / 39.35% additional — meaning the historic founder profit-extraction model needs revisiting. And from January 2026, transfer pricing rules apply to a wider definition of related parties, catching multi-jurisdiction tech groups that previously sat below the threshold.

None of this is unmanageable. But it requires a tax adviser who actually engages with these regimes — not one who sees them as something to outsource to a specialist on referral. We’re CTA-qualified and FCCA, with an active Head of Tax — Europe role at a major digital infrastructure operator. That combination is unusual in firms of our size, and it’s the practical reason tech founders end up working with us rather than with a generalist accountancy practice.

Who we work with on technology & software tax

Our typical tech client is a UK-incorporated growth-stage business — usually £500k to £20m in revenue, post-product-market-fit, profitable or close to it, with 10 to 100 employees. The sub-sectors we work most often with are:

  • SaaS and software businesses — B2B SaaS, vertical SaaS, dev tools, platform businesses, marketplaces. Pain points include R&D claim preparation, EMI for engineering teams, international VAT on cross-border SaaS, and structuring for fundraising.
  • AI and machine learning companies — model development, training infrastructure, ML platforms. R&D claims here are particularly valuable but also more scrutinised by HMRC.
  • IT consultancies and managed services — IT services firms, MSPs, cyber consultancies, system integrators. Often founder-owned, profitable, with 10–50 employees. Pain points are typically owner-managed tax planning, employee retention via shares, and capital allowances on equipment.
  • Specialist verticals — legaltech, regtech, fintech (in the software sense), climate-tech, healthtech. These businesses often face industry-specific tax considerations alongside the standard tech tax stack.
  • Platform and marketplace businesses — two-sided platforms, content platforms, e-commerce platforms. VAT treatment of platform fees, payment processing, cross-border transactions and the digital services Making Tax Digital obligations all come into scope.

We deliberately don’t lead with early-stage pre-revenue startups. The fee economics rarely work for either side — startups need cheap monthly bookkeeping, not £150-an-hour tax advisory. If that’s where you are, we’ll be honest about it and point you elsewhere.

What we actually do for technology clients

1. R&D tax relief — claims that survive HMRC scrutiny

HMRC’s compliance posture on R&D claims has hardened significantly. The Additional Information Form requirement, the senior officer attestation, and the rise in enquiry rates mean that loosely-prepared claims are being rejected or pared back at much higher rates than three years ago. We prepare claims with proper technical narratives that articulate the scientific or technological uncertainty being resolved, the qualifying expenditure analysis with proper apportionment, and the documentation HMRC expects to see if they enquire. We’re more cautious than some — we’d rather submit a smaller, robust claim than a larger one that gets pared back to nothing after a 12-month enquiry.

2. EMI schemes and equity for employees

For most tech businesses, EMI is the single most tax-efficient way to give equity to employees, and the most underused tool in the UK tax code. We handle the full setup: HMRC valuation submission, scheme rules and option agreements, the company-side EMI notification, and the ongoing annual return obligations. We also advise on alternative structures (growth shares, unapproved options, phantom equity) where EMI doesn’t qualify or where the employee profile is wrong for it. For founders, we model the BADR position on exit so the option scheme integrates with personal tax planning.

3. International structuring and cross-border tax

UK tech businesses with international customers, US investors, or overseas teams face a tax stack that sits uncomfortably between UK domestic tax, US federal/state tax, EU VAT and treaty positions. We advise on UK Ltd vs Delaware C-Corp parent structures (and the migration cost of changing later), international employer obligations for remote engineers, transfer pricing for intra-group services, place-of-supply analysis for SaaS and digital services, and treaty-based withholding planning on royalty and licence flows. For US expansion, we work alongside US CPA partners.

4. Founder remuneration, dividend planning and pensions

Owner-managed tech companies typically extract profits via a mix of salary, dividends and pension contributions. With dividend tax rates rising again from April 2026 (basic 10.75%, higher 35.75%, additional 39.35%) and pension annual allowance at £60,000, the optimal extraction mix has shifted. Employer pension contributions reduce corporation tax, are NIC-free, and don’t count against the personal annual allowance — they have become the most tax-efficient component of founder remuneration for most growth-stage tech companies. We model the extraction position annually as part of the year-end planning cycle.

5. Exit planning and BADR

Whether the exit horizon is 18 months or five years, planning for it changes what you do today. BADR (Business Asset Disposal Relief) at 18% is available on up to £1m of qualifying lifetime gains, requiring 10%+ ownership held for at least two years and the company being substantially trading throughout. The qualifying conditions are easy to break inadvertently — large investment portfolios on the balance sheet, substantial non-trading subsidiaries, or share class restructuring done without thinking about the BADR clock. We advise on the structural decisions that protect the relief.

Who this is for — and who it isn’t

This specialism is the right fit for technology and software businesses with:

  • Annual revenue in the range £500k to £20m, with a profitable or near-profitable business model
  • 10 or more employees, or a clear plan to grow there within 12 months
  • Real tax planning needs — R&D activity worth claiming, employees worth giving equity to, international customers, founders thinking about exit
  • Founders who value senior, qualified tax advice over the lowest possible monthly retainer

It’s not the right fit for:

  • Pre-revenue or very-early-stage startups with simple tax positions and tight cash — we’d be expensive overkill, and our sister firm Fernside Accounting is set up for that profile
  • Solo developers and contractors operating through personal service companies — useful tax planning is available but the work is more compliance than advisory
  • Data centre operators, hyperscale infrastructure providers and IT infrastructure businesses — we don’t take on engagements in this sub-sector
  • Businesses primarily looking for cheap monthly bookkeeping — there are good firms that specialise in that, and we’re not one of them

Real-world examples (anonymised)

Three engagements that illustrate what tech tax work actually looks like in practice:

B2B SaaS, £4m ARR, Series A funded. Previous accountant had submitted R&D claims aggressively, treating roughly 80% of engineering payroll as qualifying. Our review concluded the qualifying portion was closer to 45% — the rest was routine implementation work that wouldn’t survive enquiry. Re-prepared the current-year claim at the lower figure, refunded the over-claim from the prior period proactively, and avoided what would likely have been a multi-year HMRC enquiry with penalty exposure. Lower headline claim, but secure and defensible.
IT consultancy, 28 staff, owner-managed. Founder extracting profits via low salary plus dividends — efficient under the old rules, but with dividend rates rising in April 2026 and a £200k annual extraction need, the mix needed updating. Restructured to add £40k of annual employer pension contributions, recovered approximately £14,000 in annual tax across the founder and the company, and built a proper pension provision the founder previously didn’t have.
AI/ML company expanding to the US. Founders considering moving the parent company to a Delaware C-Corp under VC pressure. Modelled both routes including loss of EIS for existing investors, EMI scheme migration cost, US federal tax exposure of the C-Corp, and the practical exit difference. Outcome: kept UK Ltd parent, set up US Inc subsidiary instead, preserved EIS reliefs and EMI scheme, and saved the migration costs entirely. The VC ultimately accepted the structure.

Frequently asked questions

What R&D tax relief can my software company claim?
+
From April 2024, the merged RDEC scheme provides a 20% above-the-line credit for most companies. Loss-making R&D-intensive SMEs (R&D spend at least 30% of total expenditure) can claim Enhanced R&D Intensive Support (ERIS) at 27%. Software development qualifies where it constitutes a genuine advance in science or technology and resolves scientific or technological uncertainty. Routine application of existing technology does not qualify, even if commercially novel. We prepare claims with proper technical narratives and qualifying expenditure analysis.
How do EMI share schemes work for tech companies?
+
EMI (Enterprise Management Incentives) are HMRC-approved tax-advantaged share options for qualifying companies — typically those with under 250 employees and gross assets under £30m. Employees pay no income tax or NIC on grant, no income tax on exercise (provided exercise is at or above the agreed market value), and on sale the gain is taxed at CGT rates with 18% Business Asset Disposal Relief on up to £1m if held for at least two years. EMI is the most tax-efficient way to give equity to UK employees of a growing tech business. We handle the HMRC valuation, scheme rules, agreements and ongoing compliance.
Should my software business be a UK Ltd or use a US Delaware C-Corp structure?
+
It depends on funding, customer base, founder location, and exit plans. UK Ltd works well for UK and EMEA-focused businesses, qualifies for SEIS/EIS investor relief, and is straightforward to operate. A Delaware C-Corp parent (with UK operating subsidiary) is often preferred by US VCs and is structurally cleaner for a US exit, but loses SEIS/EIS, complicates EMI schemes, and brings US tax filing obligations. We model both routes and the migration cost of switching later.
How is SaaS revenue treated for VAT?
+
SaaS supplied to UK consumers (B2C) is VATable at 20% from your first £1 of UK turnover if you exceed the £90,000 threshold. SaaS supplied to UK business customers (B2B) is also 20%. Cross-border B2B SaaS to EU or US business customers is generally outside the scope of UK VAT under the place-of-supply rules — but you may have foreign VAT or sales tax obligations. EU B2C SaaS triggers OSS (One Stop Shop) registration. We map your customer mix to the right VAT treatment and registrations.
What’s the optimal salary/dividend mix for a tech founder-CEO?
+
For owner-managed tech companies, the typical optimal extraction is a small salary (often at the Secondary Threshold of £5,000/year if you have other Employment Allowance constraints, or up to the personal allowance of £12,570 if you can use it) plus dividends up to the higher-rate threshold, with employer pension contributions added on top to use the £60,000 annual allowance tax-efficiently. With dividend tax rates rising to 35.75% in the higher band from April 2026, pension contributions become significantly more attractive.
How do you handle international expansion (US/EU subsidiaries)?
+
International expansion typically involves either a branch (extension of UK Ltd, simpler but UK profits include foreign income) or a foreign subsidiary (separate legal entity, additional compliance, but cleaner separation). Each has different transfer pricing implications, withholding tax exposure, and treaty considerations. For US expansion, we work with US CPA partners on the parallel US tax setup. For EU expansion, we map the substance and permanent establishment risks under post-BEPS rules.
Are R&D tax claims still worth pursuing after the rate changes?
+
Yes — but the value has compressed significantly. Following the merged R&D scheme and rate changes effective for accounting periods on or after 1 April 2024, the relief is roughly 16-21% net of corporation tax for most claimants (lower for the loss-making R&D Intensive route, higher for the R&D Intensive small companies). Quality of claim documentation is more critical than ever — HMRC scrutiny has increased, and poorly-evidenced claims face enquiry and clawback. We prepare technical narratives that meet the BEIS guidelines and evidence the boundaries of “advance in science or technology” carefully.
What’s the difference between EMI, CSOP, growth shares and unapproved options?
+
EMI is the most tax-favoured share scheme — qualifying employees pay only 10% CGT (Business Asset Disposal Relief) on gains, with no income tax or NIC at exercise if structured correctly. CSOP is the next-best approved scheme but with lower limits. Growth shares are a separate structure entitling holders only to value above a “hurdle” — efficient at low entry value but with valuation complexity. Unapproved options have no special tax treatment — exercise is taxed at marginal rates plus NIC. The right choice depends on company stage, EMI eligibility (gross assets, employee count, qualifying trade), and the specific employees involved. We model the full position before recommending.
How does VAT work for a UK SaaS business selling internationally?
+
For B2B sales to customers outside the UK, the place of supply is generally where the customer is established — meaning UK VAT does not apply (reverse charge applies in the EU for VAT-registered customers; outside the EU, no VAT). For B2C sales to consumers in the EU, the supplier is treated as supplying in the customer’s country and may need to register for VAT in each EU country, or use the EU One Stop Shop (OSS). In the UK, consumer SaaS sales attract 20% UK VAT. The compliance can be substantial; we set up the right registrations and determine the VAT position transaction by transaction.
When does a UK tech company need to consider US tax?
+
A UK company hits US tax issues most commonly when: (1) selling to US customers and the activity creates a “permanent establishment” or US-source income, (2) hiring US employees or contractors, (3) opening a US Delaware C-corp or LLC subsidiary for fundraising, or (4) being acquired by a US buyer. Each scenario triggers different US filings (Form 5472, 1120-F, FBAR, FATCA reporting) and UK transfer pricing implications. We coordinate with US-qualified tax counsel on the complex elements and handle the UK side end-to-end.
What is the SEIS/EIS Advance Assurance process?
+
Advance Assurance is HMRC’s pre-investment confirmation that the company’s proposed share issue is likely to qualify for SEIS or EIS relief (subject to conditions being met at issue). It significantly de-risks fundraising — investors typically require it before subscribing. The application requires articles of association, business plan, structure chart, details of intended activities, prior funding history and proposed investor information. Turnaround is typically 4-6 weeks. We prepare and submit Advance Assurance applications and handle any HMRC follow-up questions.
Related Resources

Technology tax tools & insights

Explore our tools and articles to see how we think about technology tax planning.

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