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If your company is affected by the provisions, you are not subject to the restrictions on relief for payments to overseas contractors or to providers of externally provided workers. You will be able to claim ERIS, subject to a 3-year limit. Above this limit, R&D Expenditure Credit (RDEC) relief is available (to companies that meet the eligibility conditions) under the new merged scheme.

You should read this guidance if:

• you are a SME 肠濒补颈尘颈苍驳听ERIS
• your registered office is in Northern Ireland
• you have either:
  • a trade in goods, or a trade which involves relevant activities in relation to the electricity
  • no trade in goods, and your trade does not involve relevant activities in relation to the electricity, but you have not decided to opt out by notifying HMRC

Relevant activities are the generation, transmission, distribution, supply, wholesale trade and cross-border exchange of electricity.

Who can opt out

You can opt out of the Northern Ireland ERIS provisions if your business activities involve:

• no element of trade in goods
• no relevant activities in relation to the electricity market

You鈥檒l need to tell us when you provide聽additional information to support your聽R&D听肠濒补颈尘.

If you do this, the overseas restrictions will apply, but the limit on the amount of relief you can get in a 3-year period will not apply.

Overseas restrictions

For affected companies, if you鈥檙e claiming under聽ERIS, the restrictions on relief for overseas spend on contracted out聽R&D聽and externally provided workers (included at s1138A Corporation Tax Act (CTA) 2009) do not apply.

The restrictions, which limit claims for this expenditure, with some exceptions, will apply for any residual amounts for which RDEC is claimed under the merged scheme.

What a trade in goods is

You have a trade in goods if any of your business activities involves any element of trading in goods.

If you are not sure, you should proceed on the basis that you are trading in goods.

Relevant activities in relation to the electricity market

Relevant activities are the production, transmission, distribution, supply, wholesale trading and cross-border exchange of electricity.

How much you can claim under聽ERIS

ERIS relief is de minimis state aid. There is a limit to the amount of de minimis state aid that a business can receive within a given period. The 3-year limit applies to the total additional relief received by the company under the ERIS scheme, plus any other de minimis aid received by companies in the group.

This amount must not exceed 鈧�300,000 (for most businesses).

There are lower limits for certain businesses, for example those whose main activity is in the agriculture or fisheries sectors. You can contact HMRC for advice, email [email protected].

You can find out more about enhanced聽R&D聽intensive support in聽CIRD125000 鈥撀�R&D聽Tax Reliefs: reformed reliefs:聽ERIS: companies registered in Northern Ireland.

De minimis state aid means support provided under any of a number of EU regulations. The regulations are amended or replaced from time to time; at the time of publication of this guidance (19 March 2025), the following EU regulations are applicable:

• 聽(de minimis aid) 鈥� on the European Union website
• 聽(de minimis aid in the agriculture sector)
• 聽(de minimis aid in the fishery and aquaculture sector) 鈥� on the European Union website
• 聽(de minimis aid granted to undertakings providing services of general economic interest) 鈥� on the European Union website

The additional benefit amount for an聽ERIS听肠濒补颈尘 is the amount that the benefit of the claim under聽ERIS聽exceeds the benefit of an equivalent claim for聽R&D聽expenditure credit (RDEC) under the merged scheme.

Calculation to work out the additional benefit聽

Follow these steps to calculate the additional benefit.

1. Add up all the benefit amounts from the claim.

2. Subtract the net value of the鈥�RDEC鈥�鈥� that the company would have qualified for if the expenses had instead been claimed under鈥疌hapter 1A of Part 13 of the Corporation Tax Act (2009). This is the third amount covered in鈥痵ection 1042K of the Corporation Tax Act (2009), the initial amount of expenditure credit, minus the notional tax deduction.

You should include the following benefit amounts in the calculation:

• the amount of鈥�R&D鈥痶ax credit to which the company is entitled, and which it claims, for the period
• any amounts by which the liability of any other company to pay corporation tax in the period is reduced by virtue of a loss that both:
  • arises as a result of the Chapter 2 relief obtained by the company for the period
  • is surrendered by the company to the other company under鈥疨art 5 or 5A of the Corporation Tax Act 2010鈥�(surrender of relief between members of groups and consortia)
• the amount by which the liability of the company to pay corporation tax in any future accounting period is reduced by any losses carried forward from the current period which arose from the ERIS鈥痗濒补颈尘

To work out the 3-year limit

You should use the calculation show in the section, 鈥榗alculation to work out the additional benefit鈥� for ERIS鈥痗濒补颈尘s made in any previous accounting period of the company that began on or after 1 April 2024, and ended within the period of 3 years ending with the day on which the claim is made.

To this amount, you should then add the value of all other de minimis aid received in the same accounting periods by any company in the group. For example, the amount of any grant which counts as de minimis aid. You should then do this for all the amounts received in the 3 years ending with the day on which the claim is made.

If you are unsure whether or not an amount received is de minimis aid, you should ask the person or authority which provided the amount.

This should include any ERIS benefits received by any other group company, for example if another company also claims ERIS itself.

The resulting figure (all benefits, less RDEC) should not exceed the limit for the company (read the section 鈥楬ow much you can claim under ERIS鈥�).

Relief you can get for expenditure that that you cannot claim for under聽ERIS

If there is any expenditure you cannot claim ERIS for, because it would take you over the limit, you may be able to claim RDEC for that expenditure under the new merged scheme, provided you meet the rules.

You can find out more about enhanced聽R&D聽intensive support in:

• CIRD125000 - CIRD125000 鈥撀�R&D聽Tax Reliefs: reformed reliefs:聽ERIS: companies registered in Northern Ireland
• Research and Development (R&D) tax relief: the merged scheme and enhanced聽R&D聽intensive support