- Finance Act 2024 includes legislation for a new merged R&D regime to replace the existing RDEC and small and medium-sized enterprise (SME) schemes, as well as an additional tax relief for loss-making, R&D intensive SMEs (those with qualifying R&D expenditure of at least 30% of total expenditure (40% for an interim period)).
- The new merged regime provides a 20% above-the-line taxable credit, delivering a net benefit of 15% for profitable companies and 16.2% for loss making companies. Loss-making, R&D intensive SMEs will receive an additional deduction of 86% of qualifying R&D expenditure, delivering a net benefit of up to 27%.
- Under both regimes, relief is limited to UK and qualifying overseas expenditure and contracted out R&D is generally claimed by the ‘payer’ rather than the ‘doer’.
- The Labour government is expected to maintain the current structure of R&D tax credits over the next parliament as stated in Labour’s Business Partnership for Growth published in February 2024. The document also states that a Labour government will evaluate the impact of the regime on a sector-by-sector basis, starting with the life sciences industry.
- Timing: the new merged regime applies for accounting periods beginning on or after 1 April 2024, so will apply from 1 January 2025 for companies with a December year end.
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