CBILs and the Bounce Back Loan Scheme
The financial icebergs headed straight towards the UK’s SME R&D tax credits
In direct response to the Coronavirus pandemic, in March 2020 the European Commission adopted a Temporary Framework that defined and standardised the ways in which Member States can use State Aid to keep their economies afloat. It is under this framework (which runs until 31 December 2020) that the Government rushed out the Coronavirus Business Interruption Loan Scheme (CBILS) and the Bounce Back Loan Scheme (BBLS).
While these schemes have been enthusiastically welcomed by businesses, both CBILS and the BBLS are Notified State Aid, leading to concerns amongst our customers that this is going to cause some serious headaches for R&D-conducting SMEs in the not-too-distant future.
What’s the problem?
The problem is that R&D tax relief for SMEs is also a Notified State Aid, and State Aid rules prevent you using more than one form of Notified State Aid on the same project, even if they’re used at different times, and even if you pay the money back. Just think about the consequences of that for a moment.
It means that:
- If you’ve been claiming SME R&D tax credits, you won’t be allowed to use CBILS/BBLS finance to support any project that has received SME R&D tax relief.
- If you haven’t been claiming for SME R&D tax credits yet, any project that you support using CBILS/BBLS won’t be eligible for SME R&D tax credits, either now or at any point in the future.
How will my clients be affected?
The impact of this is going to vary depending on the size of the SME, the number of R&D projects they have, and their ratio of R&D costs to total costs. To illustrate the likely impacts as clearly as possible, we’ve described a few different scenarios from our perspective:
An SME with one R&D project. Most of their business expenditure relates to this single project, for which they’ve been claiming SME R&D tax relief. Let’s say that the SME spent £80k in the claim period, and £70k of this was on R&D expenditure for a single project.
Question: If the SME gets £50k from the Bounce Back Loan Scheme, how should it use this money? The answer is that because its single project has already received a Notified State Aid (in the form of SME R&D tax credits), it should only allocate the BBLS money to its non-R&D costs, or to new projects that haven’t received R&D tax relief. This leaves it in a difficult position – it can’t fund its major activity without breaking State Aid rules.
Now let’s consider an SME with multiple R&D projects, none of which have received SME R&D tax credits. How should it best use its £50k of Bounce Back funding?
Well, the worst way to do it is to spread the £50k of BBLS money across its three R&D projects, as shown below:
Why is this bad? All of the SME’s three R&D projects have now received Notified State Aid, which means that the SME cannot claim R&D tax relief under the SME scheme. While the SME can still claim R&D tax relief on all three State-Aid-funded projects, this must be done through the less-generous R&D Expenditure Credit (RDEC) scheme, which is primarily used by large companies.
So, what would’ve been a better way to use the £50k Bounce Back loan? Concentrating the £50k in as few projects as possible is the way to go. In the example below, the SME uses the £50k to fund Project 1, leaving Projects 2 and 3 unaffected by State Aid.
This means that the SME could claim R&D tax relief under the SME scheme for Projects 2 and 3, and R&D tax relief under the RDEC scheme for Project 1.
What’s the best possible scenario? If the SME is sufficiently large to have substantial running costs that have nothing to do with R&D at all, the best thing for it to do is to use its BBLS funding against those. For example, let’s say they have £80k of non-R&D costs and the same three projects as above.
This time, the SME uses the full £50k of BBLS against its non-R&D costs; this leaves its three R&D projects unaffected by Notified State Aid, meaning that it can claim through the SME R&D tax credit scheme for all of them.
Important things to remember about Notified State Aid and R&D projects
The key things to remember are:
- SME R&D tax credits, CBILS and BBLS are all forms of Notified State Aid.
- You can only use one form of Notified State Aid per project, for the entire lifetime of the project. You can’t pay back one form to get another.
- The effect of using Notified State Aid on an R&D project is to push the entire project’s expenditure out of the SME scheme and into the RDEC scheme, which gives a return of about 13p per £1 (before tax) rather than the 25-33p per £1 of the SME scheme.
- When allocating any form of State Aid to R&D projects, the golden rules are:
- If you can, first use the funding on non-R&D activities.
- Concentrate the remainder of the State Aid on as few R&D projects as possible.
SMEs in the UK are rushing towards CBILS and BBLS as ways to sustain their businesses until some form of economic normalcy returns. The problem is, very few are aware of how these schemes will affect their ability to claim for SME R&D tax relief, and many will inadvertently breach the rules. It’s not clear how HMRC will respond to that, but they may have little choice but to follow the rules as written. As always WhisperClaims will stay on top of this information and will feed back to you when more information is available.
4 commercial models for R&D consultancy adopted by accountants & consultants
Whether you’re an accountant or R&D Consultant, when it comes to delivering an R&D service to your clients, there’s a lot to consider. Delivering a great customer experience, clearly defining roles and responsibilities, managing expectations and getting it done on time are all important … but, what’s arguably even more important is making sure that the process works for you.
So what are your options and what’s best for you? Based on feedback from our customers, here’s a round-up of some observations on the various models for delivering R&D tax credit consultancy in 2020.
1. Full Outsourcing
This is the starting point for many. Most specialist R&D consultants will offer a commission to accountants for referring work to them, and this can be quite lucrative.
+ Convenience. You can concentrate on everything else on your plate, letting the specialist prepare the claim.
+ Good if you only see the occasional R&D claim e.g. 1-2 a year.
+ The specialist is usually (but not always!) responsible for defending the claim – at their cost – if HMRC raise an enquiry.
[-] Specialists are usually paid a % of the tax benefit. This means they are incentivised to make the claim as large as possible – regardless of the risks to your client. Many will ‘push the envelope’.
[-] Specialists have relationships with other accountants, and some of the accountants we speak to have had specialists refer their clients to someone else.
[-] If your client has a bad experience with the specialist, that reflects on you. Often, “bad experience” seems to relate to a recognition that the amount of work put in by the consultant didn’t reflect the fee they charged.
2. Self Delivery
In this approach, you spend time with your clients to work out the extent to which they qualify, interviewing staff, maybe looking around the premises, getting a feel for the business. You produce a report detailing the eligible work and a spreadsheet that gives a breakdown of the claim’s expenditure. This process relies upon a detailed knowledge of HMRC’s R&D tax guidance as you’ll need to interpret whether your client has relevant, eligible activities before you can account for the claim. Charging models are often on a contingent basis, from 5-30% of the tax benefit you recover for your client.
+ This model can be highly profitable if you find the right clients. Contingent fees can be in six figures for larger SMEs, and are rarely below £2k.
+ Many companies who’ve not previously claimed prefer ‘no win no fee’ arrangements, seeing it as a low risk way to access funds they weren’t expecting.
[-] Lots of people are offering this service now, so it can be hard to differentiate yourself. (Lots claim “Industry experts! 100% success rate! No win no fee!”)
[-] Fee rates are falling as competition intensifies. Depending on local competitors, you might find yourself lowering rates to rock bottom to win work.
[-] It’s time intensive, and claims can take weeks or months to prepare. Most of that is dead time, waiting for clients to respond with the information you need.
[-] Even when you’ve been authorised by your client to speak to HMRC, it can be hard to find out when the claim has been processed – and therefore know when to invoice.
3. Using Software “in-house”
This approach uses software to perform some or all of the R&D claim preparation process, and often involves using it sat alongside the client in an R&D meeting. Alternatively, you might send clients spreadsheets or Word documents to capture the information you need, then enter it into the R&D software on their behalf. You generate the report, check it for accuracy and perhaps add your own branding or content, then present it back to the client. This can help you to generate very high margins, especially if you are able to maintain a high contingent fee.
+ You may be able to keep your fees high whilst still making time-savings on the report production.
[-] It’s very slow and inefficient to ask clients questions and then manually enter their answers yourself in to the system, so this approach doesn’t work too well if you’re processing lots of claims each month.
[-] Asking a client to wade through a large spreadsheet or Word document probably isn’t the nicest experience for them, and they lose the interactive element of good software.
[-] R&D tax is a competitive market, with lots of price pressure. Your customer might ask you to justify the premium price you’ve charged them if you are spending less resource time preparing claims using technology, particularly if they are approached by multiple providers.
4. Using Software to collaborate with clients
In this approach, you’re open with your clients about using software to prepare R&D claims and you involve them in the process. You brand the software with your logo, switch on white-labelling so that the URL matches your existing domain, and invite clients to work with you remotely on the platform. You either ask them to enter the information in their own time and then check their answers, or work through the questions together online. Typically this work is charged on a competitive, fixed fee basis and is difficult for traditional competitors to compete with.
+ Your lower price makes you irresistible to local companies who’re paying higher rates to your competitors. You win new business by comfortably undercutting.
+ Asking clients to enter their information themselves is very time efficient and if you use the right software, they will be taken through a very simple, highly structured process that will ensure that they cover all of the areas that HMRC are interested in. Once they’re done, it doesn’t take long to review their answers to check for red flags.
+ White-labelling (giving the app a URL like app.myfirm.co.uk) allows you to present the system as your own, making it easier to justify your fees.
+ Clients who’ve experienced how long traditional consultancy takes will enjoy the time-savings of using software – and appreciate the lower costs of making a claim.
[-] Activating white-labelling is simple, but usually requires an IT person to set up.
[-] It can take a few claims before you get used to using software and have ironed the wrinkles out of your business process – stick with it and the benefits are there to be exploited.
There’s certainly no ‘right’ way to do things, but however you choose to do it, selecting the right model will result in higher job satisfaction for you, a better experience for your customers, and a profitable and sustainable revenue stream that helps you grow your business.
Less is more – getting it right first time
In our last blog post (‘Avoiding the elephant traps when writing R&D reports‘), we talked about how to avoid some of the common pitfalls in applying for R&D tax relief. This time we wanted to focus on the positives – the things you can include that’ll help HMRC to understand what the claim is for and give them reassurance that it’s been prepared to a high standard by someone who really understands the scheme.
The first really helpful thing you can do is decide on the structure of your report. Even if you don’t provide reams of detail, it’s useful to show HMRC that you’ve examined a wide range of factors that can affect the claim. The ones we’d particularly recommend are:
- Boundaries of R&D
- Level of detail
- Area of advance
- Competent Professionals
Be up front about any grants that the company has received. Be sure to mention the type of the award (i.e. whether it is Notified State Aid, de minimis funding, or anything else). The reason to be clear is because grants have such a significant impact on the claim, so HMRC will be keen to see that they’ve been treated correctly.
Remember, any project that’s received State Aid will be bumped into the RDEC scheme for Large Companies, meaning that subcontractor costs for Limited companies must be excluded. If the grant was de minimis State Aid (or not State Aid at all!), then the grant-funded part of the project can be claimed through RDEC and the remainder routed through the SME scheme as usual.
Boundaries of R&D
In HMRC’s playbook, R&D doesn’t actually start until you’ve set out to make something ‘better’, encountered at least one significant technical challenge, and, crucially, tried to use all the standard or existing techniques that are usually applied in that situation. If all of those don’t work, then the R&D clock starts ticking while you try to develop a new solution that does work. Getting this boundary condition right shows that you’re an R&D ninja. Getting it wrong can be an instant red flag and land you with a time-consuming enquiry.
Level of detail
Some advisors seem to think that the longer the R&D report, the stronger the claim. Not true. While it’s always important to provide a level of detail appropriate to the size of the claim, it’s usually better to provide a small amount of really concise and relevant information than a War & Peace effort where much of the information is extraneous. Like you, HMRC are pushed for time and you can help make their lives easier (and happier!) by providing only what they need to make an informed decision on your claim. Be honest about who you’re writing for – HMRC, or your client (to justify your fees..?).
Area of advance
When it comes to the section on the technical advance, it often helps to include the area of science or technology in which the advance is being claimed. Why? Two reasons – firstly, because it helps HMRC get comfortable that the advance isn’t a commercial one (for example, using existing technologies to produce something that is commercially new rather than technologically new). Secondly, being clear about the area of advance makes it easy for them to check that you or your client have Competent Professionals in that particular area.
Speaking of which, it’s good practice to consider whether the people leading the R&D projects are credible ‘Competent Professionals’. This is usually the case if they have industry experience and qualifications in that particular field. If they don’t (as is the case in many IT projects, in which non-IT experts are asked to draw up a specification for a new system but aren’t directly involved in the technical details of its implementation) then perhaps draw breath to consider whether the company should even be claiming for that work at all.
As you can probably get from the above, there’s lots to consider when making a claim for R&D tax relief – and this is only scratching the surface. The good news is that WhisperClaims provides advisors (typically accountants and business consultants) with a framework for systematically and methodically working through all of these points – and generating HMRC-compliant reports at the touch of a button. For those who like to tinker, our reports are also easy to edit and customise, allowing you to focus your efforts on the fancy icing rather than on baking the cake in the first place.
With a growing number of accountancy firms starting to use technology to make their R&D processes more efficient, the future looks like one where advisors and their clients work together closely, supported by technology, to produce stronger results with less effort and cost. And that’s a future that we’re proud to be part of.
Have you had your WhisperClaims demo yet?
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Avoiding the elephant traps when writing R&D reports
When making claims for R&D tax relief, most companies (or their advisors) will prepare a technical narrative to accompany the numbers. Ideally, this should give HMRC a clear idea of what the company is claiming for, and why it meets the criteria for relief.
Often, however, the company (or said advisor!) can fall into one of many elephant traps that are liberally sprinkled around the R&D tax credit landscape. We know that the last thing you need is to be looking up at the sky from the bottom of a dark pit (our metaphorical description of what it feels like to be facing an HMRC R&D enquiry), so have compiled this handy list of commonly made mistakes – and suggested how to solve them. Because we’re nice. And like elephants.
Trap Number 1 – Mixing up “research” with “research”.
Um, what now? Ok, I can see how this could be confusing. What we mean by this is that some companies confuse what is research for them with research as defined by HMRC’s guidelines (check out ‘HMRC CIRD81900’ for a fascinating ½ hour read).
Examples of this are companies writing things like “we’ve never done this before” or “it was difficult and required research because we didn’t know how to do this”.
The problem here is that the first question HMRC will ask is whether the company was operating outside its area of specialism. Just because they didn’t have the skills or experience to tackle the task, doesn’t mean that it is necessarily a challenge for the industry. An example of this could be an engineering company trying to claim for the development of a new IT system – they might be great at making shock absorbers, but lousy at software development.
So, if you find yourself writing ‘we didn’t know if we could do this’, be sure to explain why it was difficult and make it clear that you were operating within your sector of specialism (or if not, had at least engaged a competent professional able to recognise what is and isn’t R&D in the relevant field).
Trap Number 2 – Using the word ‘bespoke’
But wait, I hear you cry – ‘bespoke’ means unique, and unique means new, and new means eligible for R&D tax credits! Am I right?
Well, in some cases yes, but in many cases no.
The word ‘bespoke’ does indeed imply that the solution you developed is a one-off, but unfortunately that doesn’t necessarily make it eligible for R&D tax credits. Take the example of buying a bespoke suit – it’s beautiful, it’s fitted to you and only you, no other suit is exactly the same anywhere in the world.
The problem is that although the suit itself is a one-off, the process of making bespoke suits is well understood and carries no technical risk (in other words, there’s no ‘technical uncertainty’ associated with its production).
While this is a trivial example, the same principle can be applied to software projects. It’s common for companies commissioning a new IT system to think that because they’ve paid for the development of a system that’s exactly designed and configured to their specifications, that they can claim R&D tax credits for it. The issue here is that most often, the specification they set can be met by the IT company using existing techniques, methods and processes – so no R&D is involved at all!
Bottom line is, if you’re going to use the word bespoke, be prepared to explain which parts of the project or product advanced scientific knowledge. Being unique isn’t enough on its own!
Trap Number 3 – Get your boundaries right
We’ve seen some reports that are pretty expansive (or optimistic) about when R&D starts and stops. For example:
“The R&D began when the company first spoke to the client about the problem, and ended when the solution was implemented.”
Again, writing something like this is a red flag to HMRC’s Inspectors, who know that the early part of the project is likely to involve talking in more general terms about the project – its success criteria, costs and timings etc.
In contrast, the boundaries for R&D (for tax relief purposes) are defined as ‘when work to resolve the scientific or technological uncertainty starts’ and ends with ‘when that uncertainty is resolved or work to resolve it ceases’. That’s a jargon-y way of saying that you must have met a significant new technical challenge in the project – and those challenges typically don’t pop up straight away (unless you’ve been specifically engaged to solve a problem that’s known to be R&D straight off the bat).
In summary, our advice is to be careful to show HMRC that you understand the start / stop conditions of R&D. A good way of doing this is to show in the report what the client did prior to any R&D, making it more obvious that the claimant is being respectful of the limits of the scheme.
Hungry for more? Read part 2 of our blog series: “Less is more – getting it right first time”.
Or find out more about writing a technical narrative and get some examples.
Have you had your WhisperClaims demo yet?
The challenges of describing your projects in exactly the right way can be avoided by using WhisperClaims. Our award-winning R&D software makes it easy to prepare a claim, works directly from your data, and creates reports that have been specifically designed to be clear, concise, fit for purpose and as free from red flags and elephant traps as we can possibly make them.
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Don’t get bamboozled by grants
The interaction of grants and R&D tax credits is one of the least well understood parts of HMRC’s R&D Tax Relief scheme, but it doesn’t have to be – it’s actually not that bad once you understand a few basics! In this mini tutorial, we walk you through some of the key tips and rules and show you how these can be applied to your projects (or those of your clients).
The first thing to appreciate is that, from the perspective of R&D tax credits, grants can be split into two types: Notified State Aid, and then everything else (including de minimis State Aid). Notified State Aid is grant funding that has been notified to and approved by the European Commission; in fact, the SME scheme for R&D tax credits is in itself a Notified State Aid! To help prevent Governments over-subsidising their own companies, there is a rule that no project within Europe can be in receipt of more than one form of Notified State Aid. This leads us to Rule 1.
Rule 1 – You can’t use more than one form of Notified State Aid on a project.
This means that if your project has already received State Aid (such as a SMART grant), you can’t apply for R&D tax credits under the SME scheme. Technically this applies for the lifespan of the project, so accepting a State Aid grant in one year will preclude claiming SME R&D credits in all subsequent years. However, the news is not all bad! (See Rule 2.)
Rule 2 – You can claim for State Aid-funded projects through RDEC.
More of a tip than a rule, but anyway – RDEC stands for Research & Development Expenditure Credit, which is the scheme available for Large Companies (those with 500+ staff) conducting R&D in the UK.
If you are an SME with a State Aid-funded R&D project, you can normally claim relief under RDEC – which unlike the SME scheme is not a form of Notified State Aid. It doesn’t matter what percentage of the project has been funded by State Aid – all of its expenditure is affected! Here are a couple of examples.
Example 1: £100k project funded by £40k of State Aid.
Example 2: £100k project funded by £10k of State Aid.
In each example above, the whole project must be routed through RDEC, irrespective of how much State Aid it received. So be warned! As an SME, accepting even small amounts of State Aid can have a big impact on your ability to claim for R&D tax relief.
Ok, that’s the evil form of grant funding out the way. Now let’s look at what happens when we fund R&D projects with grants that are not Notified State Aid. Well hello Rule 3…
Rule 3: Non State Aid grants split your project into SME & RDEC components.
Compared with the fire-breathing dragons of State Aid, other forms of funding are much nicer, fluffier creatures. Instead of forcing your whole project into the RDEC scheme, they affect only the amount they subsidise, with the balance allowed to go through the SME scheme as usual. Let’s look at a couple of examples to get a feel for how this works.
Example 3: £100k project funded by £40k of other grants.
Example 4: £100k project funded by £10k of other grants.
In each of these examples, the part of the project subsidised by the grant is routed through RDEC. The remainder goes through the SME scheme as usual. For most companies, this is the best of both worlds – you get your grant, and you also get to claim for a lot of the SME tax credits; nice!
While there is still a bit of complexity we haven’t covered (for example, not all costs eligible under the SME scheme are permissible under RDEC), we hope that gives you a clearer idea of how grants affect claims for R&D tax credits. State Aid is ‘bad’ – but not as bad as people think, as it doesn’t stop you claiming, it just changes how much benefit you get from your claim. Non State Aid is ‘good’, in that it nourishes your projects while not preventing you from claiming for the majority of your oh-so-tasty SME R&D tax credits.
The great news is that all of the above information is baked into WhisperClaims – a robust, cloud-based system that allows you to prepare claims for your clients quickly and with as much expert knowledge as we could pack in (which was a lot).
<<<Boost your R&D knowledge with our clever guides on making a tax relief claim.>>>
De-bunking the myths on R&D tax credit claims
Despite the fact that HMRC’s R&D tax credit scheme is now close to 20 years old (how time flies!), there are still quite a few stubborn myths and questions that never quite seem to go away. To help banish them once and for all, we’ve compiled a list of three of the most common – we hope these haven’t got in the way of your claims over the years!
Myth 1: “We can’t claim for projects that failed”
Like many good myths, there’s an element of truth to this. If the project has failed for business, commercial or legal reasons (or, gulp, due to poor leadership or mismanagement) then yes, that’s not good.
If, however, the project failed for technical reasons, then from the perspective of R&D tax credits, this can actually be positive, as it shows that what you were trying to achieve was genuinely challenging, even for experienced people.
So, if projects fail, you don’t necessarily have to push them into a darkened room and forget about them.
Top tip: Instead, keep a note of why that project failed, and if it’s a technical reason, the work might be worth considering as part of your claim when you come to your year end.
Myth 2: “We can’t claim for projects that received grants”
Ooooh, this is a horrible one – and we hear it quite a lot. It’s horrible because people believe it, don’t look at how the scheme works and end up losing out big-time as a result.
Unlike Myth 1, there is no element of truth to this. You can claim for grant-funded projects, but you’ve got to do it correctly and the benefit you receive will vary depending on the size of the grant and whether it’s Notified State Aid.
As a rule of thumb, if a project has received Notified State Aid (no matter how small) then all of that project’s expenditure should be routed through the Research & Development Expenditure Credit scheme (RDEC) – that’s normally used by Large Companies.
Conversely, if you have a £100k project that’s been subsidised by a £30k grant that is not Notified State Aid, then £30k of the project would go through RDEC and £70k will go through the SME scheme.
Top Tip: The moral of the story is: find out what type of grant you received!
Myth 3: “We can’t claim for the work because we were paid to do it”
This is a really interesting one. Again, it’s based on truth, in that if you are contracted by an SME to perform R&D, you can’t claim (instead, the commissioning SME will be claiming R&D tax relief on the payment they made to their subcontractor – you).
However, the first point to make is that if you are commissioned to perform R&D by a Large Company (usually one with 500 or more staff), then you are generally able to claim through RDEC yourself, as the commissioning Large Company cannot claim R&D tax relief on the costs of its Limited Company subcontractors.
The other, more subtle point, is that many contracts between companies and their subcontractors do not explicitly state the need for R&D. In short, the contract is for a defined piece of work and the need for R&D is often not mentioned.
Now, it may be that as a subcontractor delivering such a contract, you can do what’s required by using existing knowledge, processes and techniques. In this case, no R&D is involved and it would be inappropriate to claim R&D tax relief.
On the other hand, you may decide to launch your own project – at your own cost and risk – to develop a new capability that will assist in delivering upon this contract, and similar contracts you might win in the future. In this case, there’s usually an argument to be made for claiming R&D tax relief under the SME scheme.
Top Tip: Check if the contract with your client explicitly states the need for R&D and if you have an argument for making a claim.
Don’t get bamboozled!
The great news is that all of these myths are comprehensively busted in our software platform, WhisperClaims, which was designed from the ground up by people who’ve worked in R&D tax credit consultancy for years. The software helps you evaluate work that might have failed, handles all kinds of grant situations (such as using Notified State Aid and de minimis funding on the same project, for example) and even takes you through the complexities of working as a subcontractor for other entities, whether SMEs or Large Companies.
There’s a lot going on in our system, and we feel the best way to explain it all is to show you. That’s why we’re happy to arrange a free demo and consultation, so that you can decide whether it’s right for you or your clients.
>>> Get it touch to arrange your free demo and consultation >>>
We’re off and running – a new approach to R&D tax claims!
After a hectic few months, I’m pleased to finally say that we’ve got the WhisperClaims team together and are ready to go!
Richard Edwards and Jen Smeed join as Director/Shareholders and Rick Henry as our Lead Developer.
We’ve built a fully automated software platform for the production of R&D tax claims. White labelled for Accountants and R&D Tax Specialists, we are able to produce R&D claims, from client engagement to full report production, in under an hour, all for a fixed fee irrespective of the claim size.
We’re still pre-launch (website to go live later this month) but our early adopters are already generating revenue from the platform.
A revolution? We think so.
If you’d like to know more, contact us and we’ll have a chat about how you can benefit.