Research and development (R&D) based tax incentives could encourage R&D activities which will lead to innovation and economic growth. This is important as several studies found that Indonesia is at risk of middle-income trap (MIT). Moreover, although Indonesia is one of the ten countries in Asia to be part of the top 40 R&D spending countries worldwide, the innovation capability is relatively low in ASEAN. Further studies found that providing incentives and fiscal support for R&D is one of the strategies to encounter MIT. The objective of this study is to conduct a comparative study of different tax incentives and fiscal support for R&D in different countries, along with recommendation on R&D based tax incentives and the fiscal support to be implemented in Indonesia. The general approach of this research is qualitative research with study of literature using secondary data. Studies found that the tax incentives provided in Indonesia are not particularly provided for R&D activities. However, regulations which could be applied to R&D activities have been in effect since 1990. When compared to the United States and United Kingdom, tax incentives for R&D provided by the government of Indonesia are not as attractive and appealing for companies to utilize. In addition, Indonesia does not comprehensively define qualified R&D expenditures and the related foundations. This study concludes that it is essential for Indonesia further elaborate the legal definition and requirements for R&D, adopt various tax incentives programs such as super-deduction and tax credit to support R&D, and provide incentives to targeted taxpayers (small-medium enterprises and large companies) and activities.