R&D tax credits (Forschungszulage) or ZIM?
– A choice without agony –
R&D tax credits vs. ZIM: The initial scenario
In practice, small and medium-sized enterprises (SMEs) ask themselves which national funding programme they should pursue for their research and development. These companies inevitably come across the perennial favourites KMU-innovativ or the Central Innovation Programme for SMEs (ZIM). The R&D tax credits (Forschungszulage, short FZul) have also been available to SMEs since 2020 and have been increasingly included in the comparison of options since 2021/22. But which funding instrument offers the best profile?
As an example, we will look at a medium-sized company (according to the GBER definition of SMEs, Annex 1) as a corporation with 100 employees and a turnover of €20 million, which is looking for open-topic funding for technical projects on its own initiative, which is why the two-phase KMU-innovativ with its thematically focussed calls for funding is not included in the analysis. It therefore boils down to a comparison of FZul (according to FZulG) and ZIM (individual projects). For both approaches, a basic decision is issued after the first stage.
Funding rates: The misleading sirens
The primary motivation to apply for public funding is the scope of the expected funding. Both funding programmes grant non-repayable subsidies in accordance with the GBER, either as direct subsidies after proof of use (ZIM) or as a deduction from the assessed corporation tax (FZul). While ZIM allows payments to be made during the year based on actual costs by means of interim proof of use, the payment or offsetting of FZul is linked to the company’s tax return and the assessment of corporation tax (after prior determination of FZul using an Elster application) and is therefore decoupled from the time of expenditure.
For ZIM, the differentiation of the funding rates should be emphasised as fundamentally positive (see Fig. 1), with the level of these increasing significantly, especially for cooperation projects. For the representative example given, the funding rate for the SME is identical for both funding programmes. However, it quickly becomes clear that companies wishing to utilise ZIM quickly reach the assessment limit of €690,000 in total, while a drastically higher assessment limitof $10 million per year applies to FZul.
It should also be noted that ZIM adds 100% indirect costs to the gross salaries. This means that the assessment limit of € 690 k is already reached with personnel costs of € 345 k, whereas the FZul funding does not provide for any overheads, but the total direct personnel costs, including the employer’s social security contributions, are part of the assessment amount.
Figure 1: Assessment amount (eligible costs) vs. subsidy rate (shown as a spectrum, but actually discrete). In the example, the 35% horizontal line applies to the eligible costs.
The overview clearly shows that the upper area of the plot remains empty, which is not surprising given the orientation of both funding programmes towards the R&D funding intensity ratio for experimental development (the empty upper zone is covered by competitive intensive funding, e.g. Horizon Europe).
Utilisation and state of the art
Both funding programmes place high demands on the novelty of the intended R&D results and require considerable technical risks during implementation. However, there are major differences in terms of market orientation and the initial and final state of the art. Here, the commercialisation pressure is chosen as the measure of market orientation and the objective measure of technology readiness level (TRL) for the state of the art.
While the R&D tax credit shows its full flexibility here and fills almost the entire option space, only a very narrow window can be utilised with ZIM (Fig. 2.). Both basic research and significant parts of industrial research are not addressed by ZIM. The end point must always reach TRL 8. This is closely linked to the requirement to penetrate the market quickly and gain market share. A further restriction results from the slightly contradictory requirement that ZIM projects must open up new fields of technology as a company. In principle, FZul projects should also be original; however, the application no longer requires a comparison of previous R&D at company level.
Figur 2: Commercialisation pressure as pressure for commercial exploitation vs. technology readiness level (TRL). Short-term ( ≤ 1 year, medium-term (1-3 years) & long-term (over 3 years, although not a selectable category but factually possible).
Effort and likelihood of success
The resources with which an R&D project is to be carried out and the content of the project will therefore help considerably in the concrete selection of suitable funding. In order to make a final assessment of the balanced advantages and disadvantages of FZul and ZIM, the actual effort involved in the application should be compared with the probability of success. A relative assessment to a classic Innovation Action under the Horizon Europe programme should be used here for the effort involved, which at 45 pages in Part B can be regarded as the maximum effort for a written one-stage application. Real experience can be used for the success rates (Fig. 3).
Figure 3: Application effort (effort relative to HEU, IA) vs. empirical success rate with external advice (for pre-approved projects).
This comparison at the latest makes it clear how little ZIM is worthwhile compared to FZul if the final assessment is to be made. With a much better margin of success (approx. 50% as a lower limit, formed by the lower limit of the ICT sector and 95% by e.g. clinical studies in phase I-II in the life sciences sector), the relatively clear effort required compared to ZIM is also convincing (application with 4,000 characters and a tabular work plan compared to a ZIM application with an exhaustive technical description and a market analysis).
ARTTIC’s conclusion
A very clear conclusion can be drawn in the case presented for a medium-sized company: For projects focussing on personnel costs, ZIM is more attractive on paper. However, this ignores both the effort involved in applying for funding (and in particular the documentation required for approval) and the lower probability of receiving any funding at all. Nominally, ZIM is more lucrative than the research allowance for medium-sized companies with personnel costs of up to € 345,000. However, 345 k € gross salary already represents the absolute limit for ZIM and it becomes clear how small the projects designed for this must be: approx. 1.5-2.0 FTE per year with a total duration of 3 years). With FZul, there is complete freedom with regard to the number (and exact knowledge) of project participants, their time expenditure and the level of individual personnel costs (no salary cap). A number of criteria can therefore be established on the basis of which companies can make a decision (Table 1).
Table 1: Decision support when choosing between FZul and ZIM
| Criterion | FZul | ZIM (Single projects) |
|---|---|---|
| R&D type | Unrestricted (fundamentals, ind. research, exp. development) | Limited (partial ind. research, exp. development) |
| Project purpose | open | Marketable products and commercialisable processes |
| Project duration | 3 years in advance from the date of application, but up to 7 years in total through retroactive application | Max. 3 years from authorisation |
| Lead time for application | No pre-application necessary and can still be applied for up to 4 years after the start of R&D work | Work can begin before the application is submitted (but there is a general risk that costs will not be recognised retroactively) |
| Legal claim | Qua fulfilment of Frascati criteria and formalised by decision of the BSFZ | No legal entitlement; approved projects are subject to a general reservation |
| Flexibility Costs | Full flexibility with regard to approved cost items (up to a maximum assessment amount of €10 million per year for companies), as long as the type of R&D work does not change in terms of content | Limited cost flexibility, as the assessment amount is limited to €690,000 and any changes to the amount must first be approved by the project sponsor |
Even if individual ZIM projects only make sense in a few cases compared to FZul, ZIM is a good option for SMEs to organise knowledge transfer in the form of a cooperation project with research institutions. In a co-operation project, these benefit from 100% coverage of their costs and also receive an overhead for indirect costs up to a total assessment amount of €220,000. Our colleagues at PNO Consultants can provide you with expert advice on this.
Last but not least, companies should keep an eye on the general framework conditions. Between 2021 and 2023, applicants had to endure a total of three application stops for ZIM due to budget exhaustion or a lack of budget. In contrast, the research allowance is a tax subsidy and therefore independent of the federal budget. Our ARTTIC consultants will be happy to inform you about the other advantages in a video call.
Author
Dr. Daniel Pawliczek
Funding Consultant bei ARTTIC Innovation
“Anyone who wants to advise must first and foremost listen.”
As a Funding Consultant, I help clients to benefit from German R&D tax credits. As the instrument is still quite new, I actively approach innovative companies, communicate the specifics & opportunities and analyze whether the scientific, technical and organizational requirements are met.
If you are interested in ARTTIC’s consulting services, please feel free to make an appointment with our FZulG experts.
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