Many SMEs carry out R&D activities without realising it and miss out on tax deductions worth up to 42 % of qualifying research expenditure. We identify which activities qualify, prepare the technical documentation and file applications with CDTI, AEI and regional funding bodies.
Spain's innovation-incentive framework is one of the most generous in Europe, yet also one of the most complex to activate. The R&D deduction under Article 35 of the Corporate Income Tax Act allows companies to recover between 25 % and 42 % of qualifying research expenditure, with the option of early monetisation when the company lacks sufficient tax liability. Projects endorsed by CDTI can also access soft loans at 0 % interest with grace periods of up to three years. However, the boundary between R&D, technological innovation and ordinary improvement is not always clear-cut, and a misclassification can lead to tax inspections, reassessments and interest charges.
Summum Consultoria works with SMEs in Castilla y León and the Canary Islands that invest resources in improving products, processes or software without having activated any fiscal incentive. Our starting point is an activity diagnostic: we analyse ongoing projects and determine which genuinely qualify as R&D (basic or applied research, experimental development) and which qualify as technological innovation (TI). From there we design the most efficient strategy — combining the tax deduction with a direct grant (CDTI R&D Projects, Torres Quevedo, Neotec, PERTE sectoral calls or regional-agency programmes) or activating only the deduction backed by a binding motivated report from the Ministry of Science and Innovation, which provides full legal certainty vis-à-vis the tax authority.
From identification through to final economic justification, Summum acts as the sole point of contact: we draft the technical memorandum in the language that evaluating bodies understand, coordinate the cost audit with the client's tax advisers, track the file to resolution and manage all interim and final justification reports. When a project includes digital transformation or cybersecurity components, we coordinate with Summum Sistemas so that the technical documentation is consistent across all fronts and maximises the evaluation score.
We review ongoing technical projects and classify them according to the Frascati Manual criteria and CDTI doctrine. We determine what qualifies as R&D, what as TI and what falls outside the scope, and we estimate the potential tax saving or grant amount before any resource is committed.
We select the optimal combination of instruments: Art. 35 CIT deduction, binding motivated report, CDTI calls (R&D Projects, Cooperative Projects, Neotec), AEI grants, sectoral PERTE programmes or Castilla y León and Canary Islands regional calls. Timeline, synergies and risks are documented in a funding plan.
We prepare the technical and economic memorandum in the exact format required by each body. We handle registration on the relevant portals (CDTI Online, BDNS, SIE Junta CyL), submit all supporting documentation and track the file through to the grant award decision.
We prepare periodic progress reports, coordinate cost allocation with the tax adviser, draft the final technical justification memorandum and support the client during on-site verification visits or external audits by the funding body.
The operational detail: what we deliver as part of the work and what we keep alive afterwards.
R&D/TI qualification diagnostic
Analysis of technical activities according to Frascati Manual criteria and CDTI resolutions. Written preliminary opinion with estimated qualifying expenditure.
Art. 35 CIT tax deduction
Preparation of the technical and economic file supporting the Corporate Income Tax deduction. Coordination with the tax adviser for correct activation in tax return form 200.
Binding motivated report
Application to the Ministry of Science and Innovation for the report that provides full legal certainty for the deduction vis-à-vis the Tax Agency.
CDTI projects and AEI calls
Preparation of technical memoranda for R&D Projects, Cooperative Projects, Neotec and State Research Agency calls (Torres Quevedo, Public-Private Collaboration).
Regional calls (CyL and Canary Islands)
Processing of grants from the Castilla y León Business Innovation and Internationalisation Agency (ADE) and the Government of the Canary Islands for business R&D.
Technical and economic justification
Drafting of progress and final justification reports, cost allocation (personnel, materials, subcontracting) and support during audits and verification checks by the funding body.
R&D projects often entail digital transformation: when a project involves new software, automation or cloud infrastructure, Summum Sistemas ensures technical coherence and provides additional documentation that strengthens the qualification.
R&D project results that generate a patent or utility model need protection before publication. We coordinate trade mark and patent registration within the same technical file.
View service → consultoríaCompanies accessing CDTI funding or sizeable tax deductions need governance structures that can withstand internal cost audits and accountability requirements to the funding body.
View service → sistemasWhen an R&D project includes process automation or in-house software development, Summum Sistemas provides the technical documentation that evidences the innovative nature of the work to CDTI.
View service →Qualification does not depend on having a laboratory or a formal research team. It depends on whether the activities resolve technological uncertainty that was not already solved with available knowledge. An industrial SME that redesigns a process to achieve properties no supplier could previously deliver is conducting R&D. Our preliminary diagnostic — at no upfront cost — answers this question for your specific projects.
The base deduction is 25 % of R&D expenditure, rising to 42 % for the portion exceeding the average of the previous two years. Expenditure on qualified research personnel generates an additional 17 % deduction. Furthermore, if the company lacks sufficient tax liability, it can monetise the outstanding deduction with a 20 % discount, receiving it in cash from the Tax Agency. The exact amount depends on qualifying expenditure; the initial diagnostic estimates this with no commitment.
They are compatible, but the grant reduces the deduction base: expenditure funded by public money cannot be deducted a second time. The optimal strategy depends on whether the project is more likely to obtain a direct grant or whether activating only the deduction with a motivated report is more efficient. We analyse this on a case-by-case basis.
The Tax Agency may challenge the technical qualification during an inspection and require repayment of applied deductions together with late-payment interest. The motivated report from the Ministry of Science and Innovation (regulated under Art. 35.4 CIT Act) is binding on the tax administration and eliminates that risk. We recommend obtaining it whenever the accumulated deduction is material.
CDTI R&D Projects have resolution timescales ranging from four to eight months from submission, depending on the call and the volume of applications. Regional calls in Castilla y León and the Canary Islands are generally faster. In all cases we submit the application well before the project starts, since expenditure incurred prior to submission is not eligible.