R&D Tax Credits (Merged Scheme) (Merged R&D)
TaxKiln framework
R&D Claim Eligibility Stack
TaxKiln's stacked eligibility test for the merged R&D scheme (post-April 2024) — qualifying-activity scope + competent-professional standard + technological-advance threshold + ENI test for enhanced rate eligibility.
Post-April 2024 the merged R&D scheme rewrote the eligibility surface; the TaxKiln R&D Eligibility Stack runs the four tests — qualifying-activity scope, competent-professional standard, technological-advance threshold, and ENI test — in dependency order, because most rejected claims fail at the competent-professional step rather than at the headline activity-scope check.
From accounting periods beginning on or after 1 April 2024, the UK R&D Tax Credits regime is a SINGLE merged scheme, the old SME enhanced-deduction scheme and the standalone RDEC scheme have been consolidated into one above-the-line 20% credit modelled on RDEC mechanics. The credit applies to all companies regardless of size, with the sole carve-out being R&D-intensive loss-making SMEs who may elect ERIS (Enhanced R&D Intensive Support) instead. Effective net benefit ranges from 14.7p to 16.2p per £1 of qualifying spend depending on Corporation Tax rate position.
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What this relief is, in plain English
R&D Tax Credits reward UK companies for investment in resolving scientific or technological uncertainty. The merged scheme from April 2024 gives a 20% above-the-line credit on qualifying R&D expenditure that flows through your Corporation Tax computation. The credit is treated as deemed taxable trading income and passes through a seven-step relief process. Net benefit depends on your tax position: - Paying main rate CT (25%): 15p per £1 of qualifying spend - Paying Small Profits Rate (19%): 16.2p per £1 - Paying marginal rate (26.5%): 14.7p per £1 - Loss-making (notional 19%): up to 16.2p per £1 as cash credit Loss-making R&D-intensive SMEs (R&D spend ≥30% of total operating costs) can instead elect ERIS, which is more generous, up to 27p per £1 as non-taxable cash credit.
How it works
20% above-the-line credit on qualifying expenditure
Calculate qualifying R&D expenditure (staff costs + subcontractors + EPWs + consumables + software + cloud computing). Apply 20% to get the gross credit. This gross credit is treated as additional taxable trading income on your CT600.
Seven-step relief process
Step 1: Set credit against current-period CT liability. Step 2: Apply notional CT charge, 19% (SPR) for loss-makers + small-profit companies; 25% for main rate payers. Step 3: Cap remaining payable element at £20,000 + 300% of PAYE/NIC (more generous than old RDEC formula). Steps 4-7: Sequencing rules for group surrender, carry-forward, and cash payment. Most companies get part of the credit as CT reduction + part as cash payment.
Subcontractor + EPW rules tightened
Subcontractor payments + EPWs qualify subject to the historical 65% restriction. Critical April 2024 change: subcontractors + EPWs must now be subject to UK PAYE/NIC. Overseas subcontractors/EPWs restricted to narrow 'wholly unreasonable to replicate' exceptions. Review existing overseas R&D arrangements urgently, these may no longer qualify under the merged scheme.
Additional Information Form required pre-filing
Since 8 August 2023, the Additional Information Form (AIF) must be submitted BEFORE the CT600 containing the R&D claim. The AIF includes company details, R&D activities description, scientific/technological uncertainty being addressed, breakdown of costs, and named senior R&D officer (typically a director with technical credibility, not just the accountant).
Who qualifies
- UK company within the charge to Corporation Tax (incorporated business)
- Accounting period beginning on or after 1 April 2024 (earlier periods use the old SME or RDEC scheme)
- Activities meeting the BEIS definition of R&D, seeking advance in science/technology by resolving scientific/technological uncertainty
- Qualifying expenditure on staff + subcontractors + EPWs + consumables + software + cloud computing (with category-specific restrictions)
- Additional Information Form (AIF) submitted before the CT600 containing the claim
- NOT loss-making R&D-intensive SME with ≥30% R&D-to-cost ratio (those should use ERIS instead, strictly an elective carve-out)
Interactions with other reliefs
ERIS (Enhanced R&D Intensive Support)
ERIS is the carve-out for loss-making R&D-intensive SMEs (R&D spend ≥30% of total operating costs). If eligible, ERIS gives up to 27p per £1 as non-taxable cash credit, more generous than the merged scheme's 16.2p loss-maker rate. Election is made on the CT600.
Patent Box
Patent Box (10% effective CT rate on profits from patented inventions) can apply ALONGSIDE R&D Tax Credits on the same project, different relief mechanisms on different aspects. R&D credit on input costs + Patent Box on output profits. Sequence: claim R&D credit first, then apply Patent Box to the post-R&D profits attributable to patented inventions.
Annual Investment Allowance (AIA)
AIA on plant + machinery purchased for use in R&D projects can be claimed alongside R&D Tax Credits on the staff cost of using that plant. Different reliefs attaching to different aspects of the same project, AIA on the asset, R&D credit on the operational R&D work.
Subsidised R&D
Major change under merged scheme: subsidised + grant-funded R&D is FULLY ELIGIBLE for credit (previously SME scheme blocked or restricted such relief). Companies that previously could not claim SME relief on grant-funded R&D may find that same expenditure is now fully eligible, significant change worth reviewing for R&D projects with mixed funding.
Common mistakes + audit triggers
- Failing to submit Additional Information Form (AIF) before CT600, claim is automatically invalid
- Claiming overseas subcontractor costs without meeting the narrow 'wholly unreasonable to replicate' exception
- Underestimating qualifying staff costs, pension contributions + Employer NI for R&D personnel are included; some claimants miss these
- Treating ALL software licences as eligible, only software actually used in R&D activities qualifies (not general business software)
- Filing under old SME or RDEC rules for an accounting period beginning on or after 1 April 2024 (the old schemes are superseded)
- Named senior R&D officer being the accountant with no technical credibility, HMRC has rejected claims on this basis
- Claiming relief on ordinary product development that doesn't meet BEIS R&D definition (must seek advance in science/technology + resolve scientific/technological uncertainty)
Worked example
Marek, Cardiff - sole-director Ltd Co software development consultancy with bespoke ML platform R&D (2025/26)
Year ending 31 March 2026 (first full merged-scheme accounting period). Total UK qualifying R&D expenditure £180,000 (1 director's R&D time + 1 R&D contractor on UK PAYE + cloud computing on AWS + ML training data licences). Total company profit before R&D credit: £140,000.
Calculation: **Step 1: Calculate above-the-line credit.** 20% × £180,000 qualifying spend = £36,000 gross credit. **Step 2: Notional CT charge.** Company is in marginal relief band (£50k SPR upper – £250k main rate lower). Notional charge at 25% main rate × £36,000 = £9,000 notional CT. **Net above-the-line credit value: £36,000 - £9,000 = £27,000 cash benefit.** **Step 3: Set against current-period CT liability.** Profit £140,000 with marginal relief; effective CT (before credit) ~£28,000. R&D credit £27,000 reduces CT to approximately £1,000 net. **Step 4: PAYE cap check.** Company PAYE/NIC for the period: £15,000. Cap = £20,000 + (300% × £15,000) = £65,000. Cap not breached. **Effective net benefit:** £27,000 (15p per £1 of qualifying spend at marginal rate). Without R&D Tax Credits, Marek would have paid the full ~£28,000 CT. With the credit, CT reduces to ~£1,000. **Additional Information Form filed:** before the CT600 submission. R&D activity: development of bespoke ML training pipeline for time-series anomaly detection, meets BEIS definition (advance in machine learning technique; uncertainty around whether the approach can achieve required accuracy with available training data). Named senior R&D officer: Marek (director with technical credibility, Computer Science degree + 8 years ML engineering experience).
Statute reference: Corporation Tax Act 2009 + Finance Act 2024 Part 6A (as amended). HMRC manual: CIRD80000.
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
My accounting period straddles 1 April 2024, which scheme applies?+
Can subcontractor + EPW costs still be claimed under the merged scheme?+
What's the difference between Merged Scheme and ERIS?+
Do I need to file an additional information form before claiming R&D?+
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