Taxation
Article 64 bis financing for R&D projects
Tax incentives
Turn the tax incentive generated by your R&D project into a source of external financing
Article 64 bis provides a mechanism for companies developing eligible R&D&I projects to bring external financing into the project by transferring the application of all or part of the associated tax deduction to a third-party financier.
At Bavion, we structure the process from the initial project assessment and tax qualification through eligible expenditure, financing needs, technical and economic documentation, financing agreement and subsequent project monitoring.
The procedure varies by tax territory. Bizkaia provides both Ex-Ante and Ex-Post qualification stages, while other territories operate through a prior Ex-Ante qualification process.
Article 64 bis connects three elements that must remain consistent throughout the project: technical qualification, eligible expenditure and financing structure.
Could your R&D&I project use its tax incentive to obtain external financing?
R&D project eligibility for Article 64 bis
We analyse whether the project can generate eligible R&D or technological innovation deductions and whether Article 64 bis is an appropriate financing mechanism.
Confirm the tax and technical foundations before structuring the financing
We assess whether the activities can qualify as research and development or technological innovation under the applicable foral tax regulations.
Article 64 bis does not create a separate category of eligible projects: the project must first meet the requirements applicable to R&D&I deductions.
Prior tax qualification of the R&D project
We prepare the project before or during its initial execution stage so its technical qualification and expected eligible expenditure can support the financing structure.
Establish the technical and economic basis of the project before formalising the financing
Article 64 bis financing structure and agreement
We connect the expected tax deduction with the amount, timing and conditions of third-party financing and structure the information required for the financing agreement.
Translate the tax credit into a financing structure that is consistent with project execution
We structure the economic, technical and scheduling information that must be reflected in the financing agreement and coordinate its consistency with the project qualification and planned expenditure.
Formal legal drafting and tax-legal review should be carried out or validated by the corresponding specialist advisers
Project execution, final qualification and Ex-Post process
We monitor actual project execution against the technical and economic basis used to structure the financing and prepare the final evidence required by the applicable territorial procedure.
Demonstrate that the project financed is consistent with the project that was originally qualified
Projects financed through Article 64 bis have an Ex-Post qualification stage for executed activities where a prior qualification report exists.
The resulting report is essential and binding for the financier to apply the deduction associated with the financed project in its tax return.
Article 64 bis management and project monitoring
We coordinate the technical, economic and documentary elements of the operation from initial assessment through project execution and final tax application.
Maintain consistency between project, financing and tax documentation throughout the operation
Why structure your Article 64 bis financing with Bavion?
Early project assessment
Determine technical eligibility, expected deduction and financing potential before structuring the operation.
Consistent Ex-Ante qualification
Align technical scope, project phases and expected expenditure from the beginning.
Structured financing
Connect the tax incentive with the contribution required from the financier and the project's cash-flow needs.
Technical and financial traceability
Maintain a direct relationship between project activities, expenditure and financing.
Territorial adaptation
Adapt the operation to the specific qualification and procedural requirements applicable in Bizkaia or the corresponding foral territory.
End-to-end monitoring
Maintain consistency from initial qualification through financing, execution and final tax application.
R&D tax deductions
Identify and document the R&D or technological innovation activities and eligible expenditure that generate the tax deduction on which an Article 64 bis financing operation is based.
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