Beyond the Budget: Where Do You Stand? Your RDTI Profile Under the Proposed 2028 Rules

The 2026 Federal Budget proposed sweeping changes to the R&D Tax Incentive and businesses are asking "what will this mean for us?"

If enacted, the changes will operate from 1 July 2028. Taken together, the reforms represent a new R&D tax incentive world order where every company and claim will be impacted differently. However, there are three key numbers that define how the proposed reforms will impact most businesses: revenue, company age and tax position.

While the threshold will move, company revenue still determines R&D tax offset rate access and ability to access a refundable (as opposed to a non-refundable) offset. Your tax position continues to determine whether you can fully realise a non-refundable offset, or whether the benefit is carried forward to future years. And in the new world order, the proposed 10-year rule has an impact on whether you retain access to the refundable offset.

A further change that cuts across every profile in this matrix is the proposed removal of supporting R&D activities from 1 July 2028. Regardless of your revenue, age or tax position, this will narrow the base of qualifying expenditure in virtually every claim. This should be kept of mind as you review the impacts of the proposed change son your specific circumstances.

We’ve mapped these three key dimensions across business profiles to give you a reference point on how your business might fare from 1 July 2028 onwards.

How to use this matrix

Find the row that matches your company age and current tax position, then read across to the column that matches your revenue band. Each cell summarises the net impact of the six proposed reforms on that profile, with the key drivers called out. Use this as a starting point for a more detailed conversation with your advisor.

Net positive

Low impact

Moderate impact

High impact

Very high impact

	Revenue under $20M	Revenue $20M - $50M	Revenue over $50M
Under 10 yrs | Loss-making Young company, not yet profitable	Net positive Well positioned - retains refundability and gets rate uplift Under 10 years old and under $50M turnover so retains refundable offset under proposed rules A 4.5 percentage point uplift means that the R&D tax offset rate moves from corporate tax rate (CTR) + 18.5% to CTR + 23% Was already refundable so does not currently benefit from turnover threshold change Supporting R&D removal is the primary risk to manage	Net positive The standout winner - three compounding improvements at once Currently: non-refundable above $20M at CTR + intensity-based uplift Proposed: refundable under 10 yrs, within new $50M turnover threshold at CTR + 23% Moves from intensity calculation to flat rate and gains refundability simultaneously Supporting R&D removal is the only risk to manage Watch the 10-year cliff approaching which will move you back to non-refundable	Low impact Non-refundable regardless of age - rate uplift provides some benefit Above $50M so not eligible for refundable offset under current or proposed rules Rate: CTR + intensity uplift + 4.5 percentage points means improvement on current position Intensity threshold decrease may bring more expenditure into the premium rate band But non-refundable offset still has no immediate cash value to loss making business
Under 10 yrs | Profitable Young company with tax payable	Low impact Rate improves but supporting R&D removal may offset the benefit Under 10 years, under $20M - retains refundable offset, rate moves to CTR + 23% Has tax payable so refundability is largely academic, but rate uplift directly improves claim value Supporting R&D removal is the primary risk	Net positive Good position - moves to refundable and higher rate Currently non-refundable and under intensity rate Under 10 years, $20M-$50M turnover becomes refundable under proposed rules and moves to CTR + 23% Tax payable means refundability is not used right now, but big increase in offset rate is realisable through reduced tax Refundable might be beneficial in years where tax payable is low Supporting R&D removal requires review	Moderate positive impact Non-refundable - rate uplift and intensity threshold are positive, supporting R&D removal is a risk Above $50M so not eligible for refundable offset under current or proposed rules Rate: CTR + intensity uplift + 4.5 percentage points means improvement on current position Intensity threshold decrease may bring more expenditure into the premium rate band Tax payable means the uplift is realisable; larger programs with high core intensity benefit most Supporting R&D removal is the primary risk as this could be material for programs relying on scale from supporting activities
Over 10 yrs | Loss-making Established business, not profitable	Very high impact Worst affected - loses refundability, non-refundable offset worthless if loss-making Currently: refundable at CTR + 18.5% Proposed: non-refundable at CTR + 23% Rate improves but a higher rate on a non-refundable offset is meaningless when the company has no tax liability Supporting R&D removal further narrows the base that generates zero cash Currently one of the best protected profiles under existing rules. The proposed changes represent the sharpest reversal of any profile.	Moderate positive impact Rate improves; refundability unchanged, supporting R&D removal is the key risk Currently: non-refundable at CTR + intensity uplift Proposed: non-refundable at CTR + 23% Moves from intensity calculation to flat rate - a large rate improvement once profitable Refundability position unchanged - does not benefit from the threshold change the way under-10-year businesses do Supporting R&D removal is the primary risk	Neutral impact Non-refundable regardless - rate uplift deferred Non-refundable under current and proposed rules Rate: CTR + intensity uplift + 4.5 percentage points means improvement on current position Intensity threshold decrease may bring more expenditure into the premium rate band If loss-making, the rate improvement has no immediate cash value Supporting R&D removal is the risk in a group of otherwise net neutral changes
Over 10 yrs | Profitable Established business with tax payable	Moderate positive impact Loses refundability but tax payable makes non-refundable workable Currently: refundable at CTR + 18.5% Proposed: non-refundable at CTR + 23% - loses cash refund mechanism but rate improves Tax payable means the offset is still realisable, and now at a higher rate Key risk: years where tax payable is low, the non-refundable position might start to bite	Moderate positive impact Rate improves; refundability unchanged, supporting R&D removal is the key risk Currently: non-refundable at CTR + intensity uplift Proposed: non-refundable at CTR + 23% Moves from intensity calculation to flat rate - rate improvement is real and realisable with tax payable Supporting R&D removal is the primary risk Overall: realisable net positive on rate, offset by narrower base from supporting R&D removal	Moderate positive impact Non-refundable throughout - rate uplift positive; supporting R&D removal is key risk Non-refundable under current and proposed rules Rate: CTR + intensity uplift + 4.5 percentage points means improvement on current position Intensity threshold decrease may bring more expenditure into the premium rate band Tax payable means the uplift is realisable Supporting R&D removal is the primary risk

Reading the matrix

A few patterns are worth drawing out explicitly.

The standout winner: young, loss-making businesses with revenue between $20M and $50M. This is the only profile that is unambiguously and materially better off under the proposed rules. Under current rules, these businesses sit above the $20M turnover threshold and receive no cash back. They are non-refundable and on the intensity-calculated rate rather than the flat CTR + 18.5% rate. The proposed reforms simultaneously make them refundable (under 10 years old, within the new $50M threshold) and move them from the intensity calculation to CTR + 23%. Supporting R&D removal is the only risk, and it applies to every profile equally.

Young, loss-making businesses under $20M revenue are also well positioned. They were already refundable at CTR + 18.5% under current rules and retain this under the proposed rules, with the rate moving to CTR + 23%. But they do not get the step-change of moving from non-refundable to refundable, which makes the $20M-$50M band the more significant winner.

Established businesses over 10 years old that are loss-making face the most severe impact. For businesses under $20M currently receiving the refundable offset, this is the sharpest reversal in the matrix. The switch to non-refundable treatment means the rate improvement to CTR + 23% provides no immediate cash value. A higher rate on a non-refundable offset is meaningless when there is no tax payable to apply it against. The rate improves on paper but the cash position deteriorates sharply.

Established, profitable businesses face moderate exposure across most revenue bands. Where refundability is lost, tax payable means the non-refundable offset retains real value, and at an improved rate. Supporting R&D removal remains the primary risk, and its materiality depends heavily on sector and the current core/supporting split. This split may serve to offset any benefits of increased rates.

Supporting R&D removal affects every profile in this matrix. Regardless of which cell applies to you, the removal of supporting R&D activities from 1 July 2028 will narrow the base of qualifying expenditure. The dollar impact depends entirely on your current split between core and supporting activities - review this with your advisor as a priority.

Ready to model your position? Contact us at Intellect Labs to find out exactly where you stand before the rules change.