Ian Davie
Senior Consultant
From the 1 April 2024 the new R&D Tax Merged Scheme will be live, and this is important, for accounting periods starting AFTER 1 April 2024. As way of example here are some company accounting periods and which scheme will apply:
This was to allow for companies’ time to adjust to the new scheme, rather than a straight switch to costs incurred after 1 April 2024. The new Merged Scheme will cover claims by SMEs, Large Companies, and any subsidised projects, which will make the process of claiming simpler. The rates applied are as per the current RDEC scheme, at a rate of 20%, less the corporation tax rate:
There are 2 other major changes to R&D claims, both affecting claims periods starting after 1 April 2024, subcontractor/EPW overseas spend and new rules around contracting out R&D and who can claim.
For subcontracted activity eligible costs will focus on UK spend only, and overseas expenditure will only be allowed under certain specific circumstances, and it is cheaper to do it abroad or availability of qualified staff in the UK are not valid reasons.
For overseas expenditure to be eligible the criteria that must be met falls into the following categories:
For eligible EPW (Externally Provided Workers) sited abroad can only be included as eligible R&D spend if the EPW is wholly or partially paid through UK PAYE/NI.
For contracting out R&D to a third party there is a major shift to account for the decision maker, who contemplated the R&D to be able to claim the cost of the R&D. Previously an SME company could always claim for subcontracted R&D, but a Large Company or SME with a subsided project could not include the subcontract cost in their RDEC claim, regardless of circumstance. Going forward the company, regardless of size or subsidy will be able to claim the cost of subcontracted R&D if they can show they intended for R&D to be carried out.
If you would like to discuss any of the intricacies surrounding the new R&D Merged scheme and the subcontracting changes, please get in touch today with one of our TBAT R&D tax consultants!
A detailed summary of the First-tier Tribunal’s decision in Realbuzz Group Ltd v HMRC (May 2025), focusing on the limits of HMRC’s discovery assessment powers in relation to R&D tax relief claims. We touch on key tribunal issues including the “hypothetical officer” test, the importance of adequate disclosure, and the legal protections available to taxpayers. The ruling offers important guidance for companies claiming R&D tax credits and clarifies HMRC’s ability to revisit prior-year claims.
The May 2025 Research & Development Communication Forum (RDCF) returned to an in-person format for the first time since the pandemic. Held in a historic setting with a focus on open dialogue, the forum covered key updates from HMRC, including policy changes, operational performance, and ongoing efforts to improve the R&D claims process. In this article, we share updates from the RDCF and our reflections on what it all means for businesses and advisors moving forward.
Assists organisations in accessing research and development grant funding across a range of UK and EU schemes and industry sectors.
Get In Touch