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.
Merged scheme
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
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%.
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
Section 1042I (opens in a new tab) says what happens to the credit. Each step uses only what the earlier steps leave.
The credit is first set against the company's Corporation Tax liability for the accounting period.
Notional tax is taken off the credit, at 25% or 19% as above.
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.
Any remaining credit can be set against the company's Corporation Tax for other periods.
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).
The credit can be applied to other HMRC debts of the company.
Whatever remains is paid to the company.
Worked 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.
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.
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
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
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Related advice
How UK R&D tax relief works since April 2024: the merged scheme, ERIS, what qualifies, costs, notification, the AIF and deadlines. Plain English, sourced.
Read moreERIS for loss-making, R&D-intensive SMEs: the 30% intensity test, the 186% deduction, the 14.5% payable credit, grace period and the choice against the merged scheme.
Read moreThe R&D PAYE and NIC cap limits the cash payable on an R&D credit to £20,000 plus 300% of payroll liabilities. See the formula, the IP exemption and examples.
Read moreCurrent R&D tax relief rates and thresholds in one table: merged scheme 20%, ERIS 14.5% and 30% intensity, PAYE cap, 65% rule, notification and time limits.
Read moreTell us about your R&D, any HMRC letter or your client in two minutes, then book a confidential call. No obligation. We reply the same working day.
Read moreSend 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
