The short answer
A company can often receive a grant and claim UK R&D tax relief for the same wider innovation project. For accounting periods beginning on or after 1 April 2024, the old SME subsidy restriction was not carried into merged RDEC, and HMRC states that ERIS has no restriction on subsidised expenditure. The project and every cost must still pass the R&D, expenditure, contracting, location, payment and scheme tests. Legacy periods require a separate subsidy and State Aid analysis.
Can a company receive a grant and claim R&D tax relief?
Yes. A company can often receive grant funding and claim UK R&D tax relief for the same wider innovation project. For accounting periods beginning on or after 1 April 2024, the old SME restriction for subsidised expenditure was not carried into the merged R&D expenditure credit. HMRC also states that Enhanced R&D Intensive Support has no restriction on subsidised expenditure.
That does not mean a grant makes every project cost eligible for tax relief. The company must still identify qualifying R&D activities and expenditure, apply the rules for contracted-out work, overseas activity and payment, and satisfy the conditions of the relevant tax-relief scheme. Accounting periods beginning before 1 April 2024 require a separate legacy analysis.
Planning or claiming for grant-funded R&D?
InnoFund can coordinate the funding and tax positions before project budgets, subcontracting arrangements and claim evidence are fixed.
Is R&D tax relief the same as a grant?
No. A grant is funding awarded under the rules and agreement of a particular programme. R&D tax relief is claimed through the company’s Corporation Tax position after applying statutory tax rules. They may support the same commercial programme, but they have different eligibility tests, evidence, timescales and administrators.
| Question | Innovation grant | R&D tax relief |
|---|---|---|
| How is support obtained? | Through the application, assessment and award process for a named funding programme. | Through the Company Tax Return, supported by the required claim information. |
| What defines eligible work? | The competition scope, grant offer and eligible-cost rules. | Corporation Tax legislation and the applicable science-and-technology guidelines. |
| When is it assessed? | Usually before or during the funded project, with monitoring against agreed milestones. | For the company’s accounting period, normally after costs have been incurred. |
| Does an award prove tax eligibility? | No. A funder’s innovation criteria do not replace the tax test. | The company must show qualifying R&D and qualifying expenditure independently. |
Which R&D tax rules apply to the grant?
The accounting period’s start date is decisive. The current merged scheme and ERIS apply to accounting periods beginning on or after 1 April 2024. The former SME scheme and old RDEC apply to periods beginning before that date. A period ending after 1 April 2024 can therefore still be governed by the legacy rules if it began earlier.
| Accounting period and scheme | Grant or subsidy position | Other conditions still matter |
|---|---|---|
| Merged RDEC: period beginning on or after 1 April 2024 | The former SME subsidy restriction was not carried forward. Grant-funded costs are not automatically deducted merely because they are subsidised. | Qualifying activity and costs, who contracted out the R&D, UK activity, payment condition, PAYE/NIC cap and claim process. |
| ERIS: period beginning on or after 1 April 2024 | HMRC states there is no restriction on subsidised expenditure. | The company must be a loss-making R&D-intensive SME and meet all ERIS, expenditure and claim conditions. Northern Ireland ERIS has additional aid rules. |
| Legacy SME scheme: period beginning before 1 April 2024 | Notified State Aid and other subsidies can restrict the SME claim at project or expenditure level. | The grant’s legal character, what it subsidises, project boundaries and the old SME conditions. |
| Old RDEC: period beginning before 1 April 2024 | Old RDEC did not contain the same subsidy restriction, and certain subsidised SME expenditure could potentially enter RDEC. | RDEC eligibility, qualifying expenditure, claim timing and the precise treatment of costs excluded from legacy SME relief. |
Do not apply the current answer retrospectively to a legacy claim or amendment. Identify the accounting period, scheme and grant terms before calculating the qualifying expenditure.
How do grants affect merged RDEC?
Under the merged RDEC rules, receipt of a grant does not by itself reduce qualifying expenditure. A company with £100,000 of qualifying costs does not automatically reduce that figure to £60,000 merely because a £40,000 grant contributes to the project.
The company still needs to test each cost. The merged scheme changed which party can claim contracted-out R&D. Broadly, the customer can claim where it contracts out activities intended or contemplated as R&D; the contractor may claim in specified circumstances where the customer did not contract out R&D. A grant agreement, collaboration agreement or subcontract does not override these tax rules.
How do grants affect ERIS?
ERIS provides additional relief for eligible loss-making R&D-intensive SMEs. HMRC’s current manual expressly says there is no restriction on subsidised expenditure, so receipt of a grant does not automatically exclude funded costs.
However, the company must still meet the ERIS conditions for the relevant period, including the R&D intensity test and loss-making requirement. Qualifying expenditure for the intensity calculation follows detailed rules, and a one-year grace period can apply in appropriate cases. The grant award itself is not evidence that the company meets the tax intensity test.
What changed from the old SME scheme?
Under the legacy SME scheme, notified State Aid could prevent SME relief for the subsidised project, while other grants or subsidies generally restricted the SME expenditure to the extent funded. Depending on the facts, expenditure excluded from SME relief could potentially be considered under old RDEC.
The distinction between notified State Aid, de minimis support and other subsidies was therefore central to older claims. The funding body’s name or the word “grant” was not enough: the award letter, legal basis, eligible-cost schedule and project connection had to be reviewed.
Legacy periods need their own calculation
If an accounting period began before 1 April 2024, retain the original funding agreement and advice. Later reform removed the subsidy restriction for the new schemes; it did not rewrite the treatment of an earlier period.
Does the grant-funded project define the tax R&D project?
Not necessarily. A funding programme may define a project by commercial deliverables, work packages, partners and milestones. For tax purposes, the R&D project is identified by the advance in science or technology sought and the scientific or technological uncertainties addressed.
The tax project may cover only part of the funded programme, extend across several grant work packages or stop before the commercial project ends. Equally, a grant-funded work package may be commercially innovative but fall outside tax R&D because the work does not seek an advance in overall scientific or technological knowledge or capability.
- 01
Map the commercial programme
Record the grant work packages, milestones, partners, eligible costs and funding period.
- 02
Define the tax advance
State the scientific or technological baseline, advance sought and uncertainties that competent professionals could not readily resolve.
- 03
Set the R&D boundaries
Separate directly contributing and qualifying indirect activities from routine delivery, market work and post-R&D production.
- 04
Reconcile the two views
Show which grant tasks and costs fall inside the tax project and explain any difference rather than assuming the scopes match.
Which grant-funded costs can qualify?
Only expenditure within the statutory categories and connected to qualifying R&D activities can enter the claim. Under the current schemes, the main categories include staffing costs, externally provided workers, software, consumable items, data licences, cloud computing, payments to clinical-trial volunteers and qualifying contracted-out R&D. Detailed conditions and apportionment rules apply.
| Grant budget item | Tax review | Evidence |
|---|---|---|
| Employees | Identify time spent on qualifying activities and qualifying indirect work. Exclude ordinary commercial, administrative and production activity. | Payroll records, role evidence, project records and a supportable time allocation. |
| Subcontractors and collaborators | Determine the contract chain, whether R&D was intended or contemplated, which party bears the risk, and whether overseas restrictions apply. | Signed agreements, statements of work, invoices, technical instructions and delivery records. |
| Materials and prototypes | Consider consumption or transformation in R&D and whether an item becomes part of a product sold in the ordinary course of business. | Bills of materials, test records, write-offs, production records and cost ledgers. |
| Software, data and cloud | Identify qualifying use and make a reasonable apportionment where a service also supports non-R&D work. | Licences, cloud bills, usage data, system architecture and allocation method. |
| Capital equipment | Capital expenditure is not copied into the revenue R&D expenditure categories. Separate reliefs, including R&D allowances, may need consideration. | Invoices, fixed-asset register, ownership, use and commissioning records. |
The current new schemes also impose a payment condition: otherwise qualifying expenditure must generally be paid within two years after the end of the accounting period to be brought into account. A grant reimbursement does not demonstrate that the supplier or worker was paid.
What about contracted-out R&D and collaborative projects?
Grant-funded programmes often involve universities, specialists, consortium members and connected companies. Under the post-April 2024 rules, entitlement cannot be decided only by asking which party paid the invoice. The contractual relationship and who intended or contemplated the relevant R&D are important.
Review the agreement before work begins where possible. Ambiguous work packages, intellectual-property clauses and responsibility for technical decisions can create a mismatch between the commercial funding structure and the tax position. Overseas contractor or externally provided worker costs are also subject to restrictions, with limited exceptions.
Does Northern Ireland change the answer?
Potentially. A company may elect into Northern Ireland ERIS for eligible Northern Ireland trading activity. HMRC treats that relief within a separate subsidy-control framework and requires information about de minimis aid. The company must monitor the applicable rolling three-year limit and the amount of relevant aid received by the single undertaking.
This is distinct from the general statement that ERIS has no restriction on subsidised expenditure. A Northern Ireland company, or a group with Northern Ireland activity, should check whether the ordinary UK ERIS rules or Northern Ireland ERIS apply and review other public support before making the claim.
A worked grant and R&D tax example
A UK company has an accounting period beginning 1 July 2025. It incurs and pays £100,000 of expenditure on an R&D project and receives a £40,000 grant toward the wider programme.
| Project expenditure | £100,000 |
|---|---|
| Grant received | £40,000 |
| Automatic subsidy deduction under merged RDEC or ERIS | None |
| Amount tested under the tax rules | £100,000 |
| Amount entering the claim | The portion of that £100,000 that passes the activity, category, apportionment, contracting, location, payment and scheme tests. |
The example does not say the company can claim on all £100,000, and it does not calculate the tax benefit. It shows only that the £40,000 grant is not automatically subtracted under the current subsidy rules. If the accounting period had begun before 1 April 2024, the legacy SME and State Aid analysis could change the result.
What evidence should the company retain?
Funding and tax evidence file
- The application, award letter, funding agreement and subsidy or State Aid wording.
- The approved project scope, work packages, budget, partners and variations.
- Claims to the funding body, milestone reports and evidence of grant receipts.
- The company’s accounting period and the R&D scheme applied.
- A tax-project map showing the advance, baseline, uncertainties and qualifying activities.
- A reconciliation from the grant cost schedule to the nominal ledger and R&D claim.
- Contracts and statements of work for subcontractors, collaborators and connected parties.
- Invoices, payroll, payment evidence and the method used for each apportionment.
- Evidence supporting ERIS intensity and loss-making status where relevant.
- A record of the technical and financial reviewers who approved the claim.
A strong reconciliation explains differences between the funded budget, actual project spend, statutory qualifying expenditure and the final tax claim. It should not force the grant reporting categories to serve as a substitute for the tax analysis.
How should grant and tax planning be coordinated?
Review both routes before the grant application and again before signing collaboration or subcontracting agreements. This helps the company understand cash timing, ownership of the R&D, evidence responsibilities and the effect of alternative project structures. The funding application should remain accurate to the programme; the tax analysis should remain accurate to the legislation.
One project, two evidence frameworks
InnoFund helps businesses align innovation-funding records with a technically and financially supportable R&D tax position, without treating one eligibility test as proof of the other.
For help assessing the R&D claim alongside your funding, explore our UK R&D tax relief service.
Frequently asked questions
Can you claim R&D tax credits on grant-funded work?
Often, yes. For accounting periods beginning on or after 1 April 2024, merged RDEC and ERIS do not apply the old SME subsidy restriction. The work and costs must still meet every other relevant tax condition. Legacy periods require a separate analysis.
Is an R&D tax credit a grant?
No. A grant is awarded under a funding programme. R&D tax relief is claimed through Corporation Tax under statutory rules. The same business project may access both, but one does not prove eligibility for the other.
Do I deduct the grant from qualifying R&D costs?
Not automatically under merged RDEC or ERIS for periods beginning on or after 1 April 2024. Test the gross expenditure under the current qualifying-cost and scheme rules. Different subsidy restrictions can apply to the legacy SME scheme.
Does an Innovate UK award prove that a project qualifies for R&D tax relief?
No. The award is useful project evidence, but the Corporation Tax claim must independently identify an advance in science or technology and the qualifying activities and costs.
Can a loss-making SME with a grant claim ERIS?
Potentially. HMRC says ERIS has no restriction on subsidised expenditure, but the company must meet the loss-making, SME, R&D-intensity and other ERIS requirements. Northern Ireland ERIS has additional aid rules.
Can both a customer and contractor claim the same R&D?
The current contracted-out R&D rules determine which party is entitled to claim. The answer depends on the contract and whether the customer intended or contemplated the activities as R&D; it is not decided by grant funding alone.
Can capital equipment funded by a grant go into an R&D tax claim?
Capital equipment is not copied into the revenue expenditure categories for merged RDEC or ERIS. Other capital reliefs may need consideration, subject to their own conditions and any interaction with public funding.
What if the grant relates to an accounting period before April 2024?
Apply the legacy SME and old RDEC rules. Review whether the support was notified State Aid or another subsidy, which project and expenditure it supported, and whether any restricted SME costs could qualify under old RDEC.
Check the detail
Sources & scope
United Kingdom. Current treatment applies to accounting periods beginning on or after 1 April 2024 and was checked on 5 September 2026. Earlier periods remain subject to the legacy SME and old RDEC rules. Northern Ireland ERIS, subsidy-control terms, contracted-out R&D, overseas expenditure and individual grant agreements require separate review.
This is an InnoFund explanation, not official guidance or advice on a particular claim. The facts, relevant law and applicable scheme rules must be considered together.
Sources checked: 5 September 2026. This is separate from expert sign-off.
- HMRC: Merged RDEC and Enhanced R&D Intensive Support
Current public guidance for accounting periods beginning on or after 1 April 2024
- HM Treasury and HMRC: Merger of the SME and RDEC schemes
Removal of the former SME subsidy restrictions
- HMRC: Research and Development Expenditure Credit merged scheme
Current subsidy and contracted-out R&D policy
- HMRC Corporate Intangibles R&D Manual: ERIS overview
CIRD121000; no restriction on subsidised expenditure and ERIS conditions
- HMRC Corporate Intangibles R&D Manual: legacy SME subsidised expenditure
CIRD81650; notified State Aid and other subsidy treatment for earlier periods
- HMRC Corporate Intangibles R&D Manual: old RDEC subsidised expenditure
CIRD89760; historic RDEC treatment of subsidised qualifying expenditure
- HMRC: RDEC for large companies
Public guidance for accounting periods beginning before 1 April 2024
- HMRC: Check which R&D costs can be claimed
Qualifying expenditure categories and grants or other financial support
- HMRC Corporate Intangibles R&D Manual: qualifying expenditure overview
CIRD131000; current in-house, contracted-out and contractor categories
- HMRC Corporate Intangibles R&D Manual: contractor payments
CIRD138000; qualifying contractor-payment conditions
- HMRC Corporate Intangibles R&D Manual: payment condition
CIRD132000; two-year payment rule under merged RDEC and ERIS
- HMRC Corporate Intangibles R&D Manual: Northern Ireland ERIS
CIRD125000; Northern Ireland election and de minimis aid requirements
- HMRC Corporate Intangibles R&D Manual: claims process
CIRD181000; claim, notification and Additional Information Form framework
- HMRC Corporate Intangibles R&D Manual: R&D relief timeline
CIRD98900; transition to the post-April 2024 schemes
