SOFTWARE · FIRST-TIME
A clean ledger with nothing behind it
A 120-person scheduling-SaaS company with 400+ customers on annual subscriptions. The bookkeeping was tidy — which is exactly why the gap was obvious: there was no R&D expense account anywhere, and every engineer's salary sat in cost of sales.
The real level was never below the threshold
Reconstructing staff structure put actual R&D intensity above 8% — comfortably over the 5% threshold for companies under RMB 50M. What was missing was not the spend but any auditable trail from person to project to ledger.
So the sequence was reversed: compute the true number first, then build evidence backwards. Companies that start by writing documents end up with documents that contradict the ledger.
Three breakpoints: people, money, proof
People. 68 of 120 staff were technical, but 22 were long-term on customer sites doing implementation and maintenance — under the 183-day rule they cannot count. The remaining 46 included custom-development work that is not product R&D. Roles and hours were split on two axes; anyone below 50% R&D hours in a month was excluded. Final qualifying count: 43 people, 35.8% of headcount.
Money. Cloud and bandwidth only qualify where the environment is R&D or test — production capacity earns revenue, it does not do research. Environment tags isolated about 18% of cloud spend; the rest stayed in cost.
Proof. Nine copyrights said nothing about which release they belonged to. Three major versions were split by module into separate results, each tied to a release date and contract value — 12 commercialisations over three years, four per year on average.
Why 7.8% and not 7.67%
Three-year R&D spend of RMB 6.63M against three-year revenue of RMB 85M gives 7.8%. The annual ratios were 6.6%, 7.6% and 8.8% — an arithmetic mean of 7.67%. The filing system uses the aggregate ratio, not the mean of annual ratios, and reviewers read it the same way.
The denominator is sales revenue: main business plus other operating revenue, excluding non-operating income and investment gains. Adding government grants to the denominator is a common and expensive mistake.
Result. Certified first time, four months end to end, at a 7.8% ratio — 2.8 points of headroom over the threshold.