Merged scheme & compliance
The merged R&D scheme hasn’t just changed rates and labels — it has changed what “good” looks like in practice. Strong submissions are now those with clean project boundaries, coherent disclosure across the AIF and report, and cost logic that a third party can understand quickly.
If you want your claim to process smoothly, treat compliance as an architecture problem, not a form-filling problem. Under the merged scheme, HMRC’s leverage comes from inconsistencies: mismatched projects, vague uncertainty, unclear subcontractor/EPW treatment, or cost allocations that don’t map back to the technical story. The best claims feel simple, consistent, and easy to follow.
High-yield mindset: write so an HMRC reviewer can answer three questions quickly: (1) what was uncertain, (2) what did you do to resolve it, and (3) why do the costs you’re claiming make sense.
1) What “good” looks like under the merged scheme
The merged scheme puts more emphasis on coherence. You can do legitimate R&D and still trigger avoidable friction if the claim reads like a set of disconnected statements. “Good” typically means:
- Project clarity: a small number of well-defined projects, each with a clear objective and uncertainty.
- Systematic resolution: the approach is structured (hypotheses, trials, iterations), not just “we worked hard”.
- Evidence is curated: a compact pack of artefacts supports the narrative (not a document dump).
- Cost logic is explainable: allocations map to work packages and roles with simple rationale.
- AIF alignment: disclosures match the report and computations (no contradictions or gaps).
Think “reviewer experience”
A good merged-scheme claim is one a third party can follow at speed: objective → baseline → uncertainty → approach → iterations → outcomes → cost mapping.
- Keep uncertainty specific and bounded (not broad statements like “complex technical challenges”).
- Show decision points (what changed, why, what happened) — that’s where R&D becomes credible.
- Be consistent everywhere: project names, dates, roles, and scope.
2) AIF & disclosures: how to keep it coherent
The AIF isn’t “extra admin” — it’s the structured lens through which HMRC triage and interpret your submission. Problems usually come from misalignment: the AIF says one thing, the report implies another, and the computation suggests a third.
Common AIF failure modes
- Different project framing in the AIF vs the technical narrative (or different project counts).
- Unclear subcontractor/EPW description (who did what, under what contractual arrangement).
- Cost categories described vaguely (e.g., “staff costs” without explaining mixed roles / apportionments).
- Overclaim signals (e.g., claiming broad BAU categories without showing uncertainty resolution).
Practical rule: if you change a project label, scope, or boundary in the report, update the AIF language too — and make sure your cost mapping still follows the same structure.
3) Project boundaries: reduce risk by reducing ambiguity
In compliance checks, HMRC pressure-test boundaries first — because boundaries determine whether the claim is credible. This is especially true for software and innovation-led delivery environments where R&D can sit inside broader product work.
Boundary questions you should be able to answer cleanly
- What would a competent professional have known at the outset, and why didn’t that resolve the problem?
- Where did experimentation stop and routine delivery begin?
- What were the “decision gates” (drop/continue/change) and what evidence supports them?
- How are BAU activities excluded (or why they don’t appear in the claimed cost buckets)?
Simple scoping pattern that tends to hold up
Instead of “everything we built this year”, scope R&D as a set of uncertainties with linked work packages:
- Uncertainty statement: one sentence, bounded (performance/feasibility/reliability constraint).
- Resolution work: 3–6 bullets describing trials/iterations (not features).
- Outcome: what was achieved or learned (including partial success).
- Cost mapping: roles and allocations that follow the work packages.
4) Evidence: curate a pack, don’t dump a drive
In a merged-scheme world, evidence quality is about signal and traceability. HMRC rarely needs everything — they need enough to show the work was systematic and the story is true.
A compact evidence pack that usually works well
- 1–2 page project summary (uncertainty, approach, iterations, outcomes).
- Iteration artefacts (design notes, test results, failure logs, experiment write-ups).
- Decision records (why you changed approach; why you abandoned an option).
- Architecture/technical notes where they show constraints and trade-offs.
- Linkage note connecting people/roles to work packages (so costs are explainable).
What not to do: rely on screenshots of tickets alone, or produce generic narratives without artefact support. Tickets can help, but they rarely show uncertainty resolution unless curated and contextualised.
5) Cost logic & apportionments: make it defensible fast
Even a strong technical story can be undermined if cost logic looks like reverse engineering. Under compliance, the cost question is simple: does the allocation reflect how the work actually happened?
Typical cost risks in merged-scheme submissions
- Mixed roles allocated without consistent rationale (e.g., “60% R&D” without a work basis).
- Subcontractors/EPWs included without contract clarity or correct categorisation.
- Overly granular timesheet reconstructions that don’t match how teams operated.
- Shared costs included without clear link to qualifying work packages.
Defensible apportionment in one line
Use a method you can explain in under a minute: role × work package × time period, anchored to real delivery structure.
- Prefer a small number of work packages that map to the narrative.
- Keep allocations stable unless responsibilities genuinely changed (and note when they did).
- Be ready to show 2–3 artefacts per role that demonstrate involvement in the uncertainty resolution.
6) Enquiry readiness: a calm, lightweight approach
The best way to handle enquiries is to reduce the probability of one — but also to be ready if it happens. You do not need heavy governance; you need consistent structure and a tidy evidence trail.
A simple monthly rhythm that works
- Maintain a short project log (objective, uncertainty, key iterations, outcomes).
- Save 3–5 artefacts per project as you go (not at year-end).
- Keep a note of role allocations and major responsibility changes.
- Ensure AIF language stays aligned with how you’re describing the project internally.
Outcome: when filing time comes around, you’re curating and editing — not reconstructing. And if HMRC asks questions, you can respond with clarity rather than panic.
7) A practical pre-submit checklist
Before you file, run this quick consistency check — it catches most avoidable issues that lead to questions or delays:
- Projects: same project count/names across report, AIF and internal notes.
- Uncertainty: each project has a specific, bounded uncertainty (not vague statements).
- Iterations: at least 2–3 clear decision points with evidence references.
- Boundaries: BAU activities excluded and explained (explicitly or by clean scoping).
- Costs: allocations map to roles/work packages and can be explained quickly.
- Third parties: contracts support the way costs are treated (subcontractor vs EPW etc.).
- Presentation: computation and accounts treatment are clear and consistent.
Want a partner-led sense-check before you file?
If you’re preparing a merged-scheme submission, we can review your draft narrative, AIF alignment, and cost logic for clarity and consistency — and suggest practical refinements that reduce avoidable processing questions.
Partner-led tax advisory for innovators & industry disruptors
We help ambitious companies access innovation incentives with clarity and confidence — combining technical understanding, defensible methodologies, and practical guidance that stands up to real-world HMRC scrutiny.
What we do
Westlock Partners provides specialist, partner-led advisory across innovation incentives and corporate tax — with a focus on making claims coherent, explainable, and processing-ready.
R&D Tax Relief
Eligibility, project scoping, AIF alignment, and robust supporting documentation — built for the merged scheme environment.
Capital Allowances
Technical reviews to identify qualifying expenditure and strengthen the evidence trail behind claims and classifications.
Grants & Funding Support
Pragmatic assistance on positioning, technical narratives, and substantiation — particularly for innovative SMEs.
How we work
Our approach is deliberately partner-led. We keep the process efficient for your team, while maintaining the depth and structure that makes a claim defensible.
Senior leadership team
Our senior team combines corporate tax expertise with hands-on technical insight — supporting everything from early-stage innovators through to complex, high-scrutiny claims.
Soroush Emami
Soroush began his professional career in practice, advising SMEs and high/ultra-high net worth individuals on compliance requirements and compliant tax planning aligned to their circumstances and ambitions. He later specialised in Innovation Incentives and Capital Allowances, working across a wide client base — from small-scale start-ups to premier league football clubs and global household brands — advising on eligibility, claim strategy, and defending claims through HMRC compliance checks, including interactions with HMRC’s Fraud Investigation Service.
Saifur Rahman
Saifur leads our technical R&D tax relief advisory practice. He is a software developer by background and holds a Master’s degree in Computer Science & Network Security from the University of Birmingham. He has specialised in Innovation Incentives advisory for the past seven years, advising Software & Technology companies on eligibility and preparing the supporting documentation required to access relief. Saifur takes a hands-on approach, proactively educating clients through workshops and training seminars to build more efficient, repeatable processes for future years. His client portfolio spans high-street banks, global fintech firms, IT transformation businesses, and early-stage tech start-ups.
Who we support
We work with innovative SMEs and growth-stage businesses — particularly those where the technical story matters and the evidence needs to be clear, coherent, and defensible.
Prefer a partner-led view before you file?
If you’re preparing a merged-scheme submission, we can sense-check your narrative, AIF alignment, and methodology — and share practical refinements that support smoother processing and stronger defensibility.
Partner-led tax advisory for innovators & industry disruptors
We help ambitious companies access innovation incentives with clarity and confidence — combining technical understanding, defensible methodologies, and practical guidance that stands up to real-world HMRC scrutiny.
What we do
Westlock Partners provides specialist, partner-led advisory across innovation incentives and corporate tax — with a focus on making claims coherent, explainable, and processing-ready.
R&D Tax Relief
Eligibility, project scoping, AIF alignment, and robust supporting documentation — built for the merged scheme environment.
Capital Allowances
Technical reviews to identify qualifying expenditure and strengthen the evidence trail behind claims and classifications.
Grants & Funding Support
Pragmatic assistance on positioning, technical narratives, and substantiation — particularly for innovative SMEs.
How we work
Our approach is deliberately partner-led. We keep the process efficient for your team, while maintaining the depth and structure that makes a claim defensible.
Senior leadership team
Our senior team combines corporate tax expertise with hands-on technical insight — supporting everything from early-stage innovators through to complex, high-scrutiny claims.
Soroush Emami
Soroush began his professional career in practice, advising SMEs and high/ultra-high net worth individuals on compliance requirements and compliant tax planning aligned to their circumstances and ambitions. He later specialised in Innovation Incentives and Capital Allowances, working across a wide client base — from small-scale start-ups to premier league football clubs and global household brands — advising on eligibility, claim strategy, and defending claims through HMRC compliance checks, including interactions with HMRC’s Fraud Investigation Service.
Saifur Rahman
Saifur leads our technical R&D tax relief advisory practice. He is a software developer by background and holds a Master’s degree in Computer Science & Network Security from the University of Birmingham. He has specialised in Innovation Incentives advisory for the past seven years, advising Software & Technology companies on eligibility and preparing the supporting documentation required to access relief. Saifur takes a hands-on approach, proactively educating clients through workshops and training seminars to build more efficient, repeatable processes for future years. His client portfolio spans high-street banks, global fintech firms, IT transformation businesses, and early-stage tech start-ups.
Who we support
We work with innovative SMEs and growth-stage businesses — particularly those where the technical story matters and the evidence needs to be clear, coherent, and defensible.
Prefer a partner-led view before you file?
If you’re preparing a merged-scheme submission, we can sense-check your narrative, AIF alignment, and methodology — and share practical refinements that support smoother processing and stronger defensibility.