In tax and accounting, few phrases are as dangerous as SALY, short for “Same As Last Year.”

SALY is the practice of repeating prior year tax positions without reassessing whether they still reflect current law, guidance, or best practices.

When teams default to SALY, they assume that last year’s approach is still correct. Sometimes it is. Often, it is not. In areas like the R&D tax credit, that assumption can quietly cost companies millions in missed credits or expose them to unnecessary audit risk.

This post explains why SALY persists, why it breaks down, and what to do instead.

Why SALY Is So Appealing

SALY exists for understandable reasons.

Accounting and tax work reward consistency. Repeating prior-year approaches feels efficient, defensible, and low-risk, especially under time pressure or when teams are understaffed. If a position passed review last year, it must be acceptable this year. Right?

Early in my career, I saw how deeply ingrained this thinking can be.

I had prepared a corporate return and submitted it for review. The numbers were correct and the workpapers tied. But the reviewer flagged an issue not with the data but with how the schedule looked. A software update had changed the formatting.

Her guidance was simple. Recreate last year’s schedule manually so it would look the same.

The concern was not accuracy. It was a deviation.

That moment made something clear. SALY is not about correctness. It is about comfort.

When SALY Becomes a Liability

SALY can be helpful for routine, stable processes. It breaks down in areas that are complex, evolving, and judgment-heavy, like the R&D tax credit.

SALY does not account for:

• Changes in tax law or case law

• New IRS guidance or administrative practice

• Shifts in how qualifying activities are defined

• Advances in documentation and analysis technology

As a result, companies often inherit outdated assumptions without realizing it.

In the R&D credit, material changes occur almost every year. What qualified last year may qualify differently this year. New opportunities may exist that were not captured before.

A notable example involved changes to how pilot models were defined and qualified. These changes allowed many taxpayers to significantly increase qualified supply costs. Yet countless companies, and their advisors, missed the opportunity entirely because they followed prior year studies without reassessing the underlying assumptions.

The result was substantial credits left on the table.

SALY Is Not a Strategy

SALY only looks backward. It cannot help you evaluate whether your current approach reflects today’s rules, risks, and opportunities.

For companies that rely on R&D credits as a material source of cash flow, SALY is not a strategy. It is a blind spot.

If your process begins and ends with last year’s report, you are optimizing for familiarity, not accuracy.

What to Do Instead

A modern R&D credit approach requires:

• Annual reassessment of qualifying activities and costs

• Documentation that reflects current guidance and expectations

• Technology that enables deeper, more consistent analysis

• Expert review that challenges assumptions rather than inherits them

At SPRX Technologies, we built a platform designed to replace SALY with a repeatable, evidence-based process supported by experienced industry experts who stay current with the credit.

The goal is not change for the sake of change. The goal is confidence that your R&D credit reflects what your business actually does today, not what it did last year.

If you want to understand whether SALY is limiting your R&D credit, we are happy to talk. Get in touch.