This is a term often encountered in documents published by the Big Four (Deloitte, Ernst & Young, Price Waterhouse Coopers, KPMG), for instance in the E&Y 2018 Worldwide R&D Incentives Reference Guide.

However, I've been unable to find a definition, formal or other, anywhere on the web for this term. I would associate it with superannuations (sometimes called super), but this doesn't seem to make a lot of sense here. Another possibility would be that it is some sort of tax deduction, reducing your taxable income, and this seems more likely, but I still don't understand the super part then.

Would anyone be so kind as to explain the meaning of this term in the context in which it is used by the Big Four?


Deloitte managed a semi-intelligible explanation. It's called "super" when an income tax deduction is applied twice for the same item (e.g. for R&D)...

In early 2015, Slovakia introduced a new type of tax incentive aimed at supporting companies conducting corporate R&D (most common is development of new or substantially improved products, services, technologies and processes). [...] Similar regimes have been in use for years in the world's most advanced economies.

In practice, eligible expenses can be deducted from the tax base twice. First as a normal tax-deductible expense and second as an additional super-deduction. [...]

Super-deductions can be utilized by any company, which in the relevant tax period incurs expenses directly related to R&D projects. In case of tax losses, the super-deduction may be transferred to the next tax period (up to maximum of four subsequent years).

KPMG has a more concise definition and some examples/figures:

Income tax is reduced by deducting R&D expenses from the tax assessment basis by more than 100% (“super deduction”) or from the tax liability (“tax credit”). [...]

Tax-free amounts are applied to obtain a discount of more than 100% of the qualifying R&D costs. From a practical perspective, this is usually achieved by deducting these costs against tax more than once. The majority of multipliers in other jurisdictions are between 130% and 210%. This leads to the fact that these increased R&D expenses can be also claimed as expenses for tax purposes and reduce the taxable profit accordingly.

  • $\begingroup$ So is it a deduction applied twice identically or in different ways? I understand how income tax deductions work, but how can you deduce R&D expenses twice? Is the defining characteristic of a super deduction the fact that it is deduced twice or that it represents more than 100% of the R&D expenses? Are these two things equivalent? $\endgroup$ – David Cian Mar 1 '20 at 13:07
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    $\begingroup$ @DavidCian: yeah, the two definitions I quoted are slightly different, as one could have two deductions that don't add up to even 100%, but it seems to me in the usual they do exceed 100% combined. $\endgroup$ – Fizz Mar 1 '20 at 13:10

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