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Merged scheme

The merged scheme: a 20% credit, taxed, then used in a set order.

For accounting periods beginning on or after 1 April 2024, most R&D claims are made under the merged R&D expenditure credit. This page explains the credit, the notional tax deduction, the order in which the credit is used and what it is worth.

How it works

From qualifying cost to net benefit

The company earns a credit of 20% of its qualifying R&D expenditure. The credit is a taxable receipt of the trade. The legislation allows for that through a notional tax deduction, so the benefit you actually keep is lower than 20%.

  • Main rate payers: notional tax at the main rate of 25%. By our arithmetic, the net benefit is 15% of qualifying costs.
  • Loss-makers and small profits companies: notional tax at the small profits rate of 19%. By our arithmetic, the net benefit is 16.2%.

Whether the main rate or the small profits rate applies is decided by whether the company has profits chargeable at the main rate, ignoring the credit. HMRC's manual (CIRD112100 (opens in a new tab)) confirms that a company entitled to marginal relief still has profits chargeable at the main rate, so it takes notional tax at 25%. Only companies with profits at or below the lower limit, and loss-makers, use 19%.

Sources: Corporation Tax Act 2009, section 1042H (opens in a new tab) (taxable) and section 1042K (opens in a new tab) (notional tax); HMRC guidance on the merged scheme (opens in a new tab).

Order of use

Seven steps, in this order.

Section 1042I (opens in a new tab) says what happens to the credit. Each step uses only what the earlier steps leave.

  1. 1. Corporation Tax of the same period

    The credit is first set against the company's Corporation Tax liability for the accounting period.

  2. 2. Notional tax deduction

    Notional tax is taken off the credit, at 25% or 19% as above.

  3. 3. PAYE and NIC cap

    The amount that can be paid out is capped at £20,000 plus 300% of relevant PAYE and NIC liabilities, unless the company is exempt. Any excess is carried forward to the next accounting period. See the PAYE cap page.

  4. 4. Corporation Tax of other periods

    Any remaining credit can be set against the company's Corporation Tax for other periods.

  5. 5. Optional group surrender

    The company may surrender what is left to another group company. Payments between group companies for surrendered credit made on or after 26 November 2025 are ignored for Corporation Tax and are not distributions (Finance Act 2026, section 31).

  6. 6. Other amounts owed to HMRC

    The credit can be applied to other HMRC debts of the company.

  7. 7. Payment of the balance

    Whatever remains is paid to the company.

Worked examples

Two simplified examples

These are our own arithmetic, from the rates above, to show the mechanics. They ignore group surrender and other HMRC debts, and are not a prediction for your company. The benefit calculator lets you try your own numbers.

A profitable main-rate company

Qualifying costs of £100,000 give a credit of £20,000. Notional tax at 25% is £5,000, leaving a net benefit of £15,000, which first reduces the company's Corporation Tax bill.

A loss-making company

Qualifying costs of £100,000 give a credit of £20,000. Notional tax at 19% is £3,800, leaving £16,200. If the company's relevant PAYE and NIC liabilities were £10,000, the cap would be £20,000 plus £30,000, or £50,000, so nothing is blocked and £16,200 is available to be paid. With a higher claim relative to payroll, the cap would bite.

Choosing between the merged scheme and ERIS

Not always the obvious answer

A loss-making SME with R&D intensity of at least 30% may choose ERIS, which can pay up to about £27 per £100 of qualifying costs. Everyone else uses the merged scheme. The qualifying cost rules are the same for both, so the choice is a calculation, and we do it for you. Government guidance puts the overall range at between £15 and £27 for every £100.

See R&D tax rates and thresholds for the current figures, and how to claim for the process. Every claim we prepare is reviewed and signed off by a Chartered Tax Adviser.

FAQs

Frequently asked questions

What is the merged R&D expenditure credit?

It is the main R&D relief for accounting periods beginning on or after 1 April 2024. It replaced the old RDEC and SME schemes. The company receives a credit equal to 20% of its qualifying R&D expenditure. The credit is a taxable receipt of the trade and is applied in a set order against the company's tax liabilities before any balance is paid to it.

Why is the merged scheme credit taxable?

The legislation treats the credit as a taxable receipt of the trade. That is why the net benefit is lower than the headline 20%. The tax effect is built into the calculation through a notional tax deduction, so the company does not need to compute a separate tax charge on the credit. The calculator and rates page show the effect in numbers.

What is the notional tax deduction?

It is an amount taken off the credit to reflect the Corporation Tax the credit would attract. Under section 1042K, it is charged at the main rate, 25%, if the company has profits chargeable at the main rate ignoring the credit, and otherwise at the small profits rate, 19%. It is step two in the order of use.

Why does a loss-maker net 16.2% but a main-rate company 15%?

Because the notional tax rate differs. By our arithmetic, a 20% credit less 25% notional tax leaves 15% of qualifying costs, and a 20% credit less 19% leaves 16.2%. The loss-making or small profits company pays notional tax at the lower rate, so it keeps more. These net figures are before the PAYE cap and other limits.

How does the credit reduce our Corporation Tax bill?

The first step in the order of use is to set the credit against the Corporation Tax of the same accounting period. After that, the notional tax deduction is taken, then the PAYE cap applies. So a profitable company will normally see its Corporation Tax bill fall first, and only a balance would be considered for payment.

Can a loss-making company receive the merged credit as cash?

Yes, but only after the earlier steps. Any balance after the Corporation Tax, notional tax and PAYE cap steps, and after any other period's tax, group surrender and other HMRC debts, is paid to the company. A loss-maker with little Corporation Tax therefore often has a balance, though the PAYE cap can limit it.

What happens to credit blocked by the PAYE cap?

The excess over the cap is carried forward to the next accounting period, where it can be used again. The cap is £20,000 plus 300% of the company's relevant PAYE and NIC liabilities, unless the company is exempt. Our PAYE cap page explains the formula and the exemption for companies that create or manage their own IP.

Can the credit be surrendered to another group company?

Yes. Step five of the order of use is an optional group surrender, so the credit can be surrendered to another company in the group. Group companies often agree a payment for the surrender. Finance Act 2026 section 31 deals with how such payments are treated. It applies to payments made on or after 26 November 2025.

Are payments for a surrendered credit taxed?

For payments on or after 26 November 2025, Finance Act 2026 section 31 provides that payments between group companies for surrendered expenditure credit, up to the amount surrendered, are ignored for Corporation Tax and are not distributions. Payments made earlier are outside that rule, so the date of payment matters. Take advice before agreeing a group payment.

Is the merged scheme the same as the old RDEC scheme?

It builds on it, but it is not the same. The old RDEC applied mainly to large companies and, for expenditure from 1 April 2023, paid 20%. The merged scheme applies the same 20% rate to companies of any size for periods beginning on or after 1 April 2024. SMEs lost the old SME deduction and now use the merged scheme or ERIS.

Can an SME choose the merged scheme instead of ERIS?

Yes. An SME that qualifies for ERIS may use the merged scheme instead, but not both for the same costs. Which is better depends on losses, the PAYE cap and the notional tax position. We model both. A loss-making SME with intensity of at least 30% often finds ERIS pays more, but that is not automatic.

How do ring-fenced trades differ?

HMRC's guidance gives different rates for ring-fenced trades. The standard 20% rate and the notional tax figures on this page apply to ordinary trades. If your company has a ring-fenced trade, tell us at the outset and we will check the rates that apply to it before any figure is quoted to you.

How do other HMRC debts affect any payment?

Step six of the order of use applies the credit to other amounts the company owes HMRC before the balance is paid. If you have an unpaid PAYE or VAT bill, for example, part of the credit may go towards it. A company with arrears should expect less cash than the headline calculation suggests.

In what order is the merged credit used?

Section 1042I sets seven steps: Corporation Tax of the same period, the notional tax deduction, the PAYE and NIC cap, Corporation Tax of other periods, optional group surrender, other HMRC debts, and finally payment of any balance. Each step only uses what the earlier ones leave, so the order can change the amount paid.

Do large companies claim under the merged scheme?

Yes. The merged scheme is the route for large companies as well as SMEs. The qualifying cost rules are the same for the merged scheme and ERIS, and the credit rate is 20% whatever the company size. Larger companies are more likely to be profit-making and to use the credit against Corporation Tax, rather than receiving cash.

Want the numbers for your company?

Send us your accounting period, qualifying costs and payroll, and we will tell you which scheme applies and what it is worth. We reply the same working day.

Or write to taxadvisory@aswatax.co.uk

Last reviewed 11 October 2026
Chartered Tax Adviser
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