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Changes in R&D tax relief following the Autumn Statement

Chancellor Jeremy Hunt has provided an unsettling Autumn Statement for innovative small companies in the UK, with the R&D tax credit scheme being a major tax area highlighted for change. Here, Iain Butler analyses how the recent Autumn Statement will impact the relief.

Unlike many of the other tax and spending changes that have been deferred to 2025, the major reduction in cashback benefit for loss-making SMEs will kick-in next year. As it stands, the proposed changes are diverting benefits from the SME scheme into the large company R&D Expenditure Credit (RDEC) scheme in an attempt to increase R&D spend in the UK. But it was also noted that an additional factor in slashing the SME benefit was an attempt to reduce the appeal of the SME scheme to fraudsters. 

The Chancellor has stated his plans for the SME R&D tax relief scheme with the additional enhanced deduction rate to be reduced to 86%, and the payable credit rate to 10%. Tables one and two show these new changes and the possible benefit to companies claiming R&D tax relief on the SME scheme.

Table one: Changes in the SME Scheme following the Autumn Statement for a loss-making company

SME Scheme Enhanced deduction Payable credit Benefit
1 April 2015 230% 14.5% 33.4%
1 April 2023 186% 10% 18.6%

Table two: Changes in the SME Scheme following the Autumn Statement for a profit making company

SME Scheme Enhanced deduction Corporation tax Benefit
1 April 2015 230% 19% 24.7%
1 April 2023 186% 25% 21.5%

He also spoke of his plans for the RDEC scheme where the payable credit rate is expected to rise to 20%. Table three shows the new changes and the possible benefits to companies claiming under the RDEC.

Table three: Changes in the RDEC Scheme following the Autumn Statement

RDEC Scheme Payable credit Corporation tax Benefit
1 April 2020 13% 19% 10.5%
1 April 2023 20% 25% 15%

The rate changes will affect expenditure on or after 1 April 2023. The decision for the reforms were highlighted as the need to improve the competitiveness of the RDEC scheme to increase overall R&D investment, as well as a step towards a simplified, single RDEC-like scheme for all. It was also discussed that ahead of the next budget, the government will work with industry to understand whether further support is necessary for R&D intensive SMEs. 

About the author

Iain Butler

+44 (0)20 7556 1343
butleri@buzzacott.co.uk
LinkedIn

Unlike many of the other tax and spending changes that have been deferred to 2025, the major reduction in cashback benefit for loss-making SMEs will kick-in next year. As it stands, the proposed changes are diverting benefits from the SME scheme into the large company R&D Expenditure Credit (RDEC) scheme in an attempt to increase R&D spend in the UK. But it was also noted that an additional factor in slashing the SME benefit was an attempt to reduce the appeal of the SME scheme to fraudsters. 

The Chancellor has stated his plans for the SME R&D tax relief scheme with the additional enhanced deduction rate to be reduced to 86%, and the payable credit rate to 10%. Tables one and two show these new changes and the possible benefit to companies claiming R&D tax relief on the SME scheme.

Table one: Changes in the SME Scheme following the Autumn Statement for a loss-making company

SME Scheme Enhanced deduction Payable credit Benefit
1 April 2015 230% 14.5% 33.4%
1 April 2023 186% 10% 18.6%

Table two: Changes in the SME Scheme following the Autumn Statement for a profit making company

SME Scheme Enhanced deduction Corporation tax Benefit
1 April 2015 230% 19% 24.7%
1 April 2023 186% 25% 21.5%

He also spoke of his plans for the RDEC scheme where the payable credit rate is expected to rise to 20%. Table three shows the new changes and the possible benefits to companies claiming under the RDEC.

Table three: Changes in the RDEC Scheme following the Autumn Statement

RDEC Scheme Payable credit Corporation tax Benefit
1 April 2020 13% 19% 10.5%
1 April 2023 20% 25% 15%

The rate changes will affect expenditure on or after 1 April 2023. The decision for the reforms were highlighted as the need to improve the competitiveness of the RDEC scheme to increase overall R&D investment, as well as a step towards a simplified, single RDEC-like scheme for all. It was also discussed that ahead of the next budget, the government will work with industry to understand whether further support is necessary for R&D intensive SMEs. 

Our concerns

Our concerns

Our concern is that, in addition to large UK companies, the other big winners are the Netherlands and Ireland, or possibly any European country that now has a more generous R&D incentives package than the UK. In the past, a major selling point of the UK as a location for innovative start-ups has been the stability of the incentives provided. The Autumn Statement has rather shattered that reputation. 

Our R&D team were approached by several companies on the day of the Autumn Statement making comments about possibly looking for other locations. Small businesses are the bedrock of the UK economy, and start-ups are obviously the large companies of the future. We feel that these changes risk damaging this important part of the economy and the government is misunderstanding the importance of R&D tax credits to the SMEs in their battle to grow and prosper in the post-COVID world. We hope that SMEs express their concerns to HMRC and Treasury to force a rethink to the scale and nature of the changes proposed. Reducing the scheme’s benefit to lower fraud is an extreme move, and is harsh on SMEs that rely so heavily on the scheme.

The Chancellor reassured MPs that these scheme changes will not have a detrimental impact on the level of future R&D investment. This is purely based on the R&D investment additionally generated by the RDEC scheme, where each pound given to the large company encourages them to invest more of their cash reserves in R&D when compared to start-up SMEs. Unfortunately, this analysis misses an important point that SMEs are sitting on a finite amount of cash and have minimal ability to increase spending due to the R&D claim cashback. However, restricting this cash injection into a start-up will very likely lead to more businesses running out of money before their product is commercialised or taking longer to develop the product when compared to overseas competitors. Unfortunately, when a policy is simply looking at one KPI, R&D spend per GDP, this can distort policy to the detriment of many highly innovative businesses. 

Let’s end with some good news. The reforms of expanding qualifying expenditure to include data and cloud costs and refocusing support towards innovation in the UK proposed in the Autumn Budget 2021 will be legislated for in the Spring Finance Bill 2023. We will run through these changes in our January R&D tax credits event. 

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