R&D tax relief
R&D tribunal case tracker: journalist pack
Everything you need to report on or reuse the tracker's 11 First-tier Tribunal decisions: what the figures do and don't show, one table of every case, the data as CSV and JSON, and how to cite it. The data is free to reuse under CC BY 4.0.
Cite this dataset: Parker, A. (2026). UK R&D Tax Relief First-tier Tribunal Case Tracker: Verified Tax Chamber Decisions. Zenodo. https://doi.org/10.5281/zenodo.22753345
The figures
11 decisions, 2020 to 2025, none yet under the current rules
- 11 First-tier Tribunal (Tax Chamber) decisions on R&D tax relief, decided between 2020 and 2025.
- 6 went for the taxpayer, 4 for HMRC and 1 in part.
- 10 concern claims under the old SME scheme and 1 under the old RDEC. None concern the merged scheme or ERIS, which apply to accounting periods beginning on or after 1 April 2024.
- HMRC's argument that client-funded R&D was "subsidised" or "contracted out" lost in all three cases where it was the main question.
- It is a researched set of decisions we could verify, not a live feed of every R&D appeal. New decisions aren't added automatically.
Read the outcomes by what was argued
A taxpayer win doesn't always mean the R&D claim stood
Counting wins and losses across all 11 cases mixes very different disputes. In 2 of the 6 taxpayer wins, the appeal was about a penalty or HMRC's assessment powers, not whether the work was R&D. In Realbuzz the tribunal found the R&D claim was excessive and still allowed the appeal, because HMRC had used a discovery assessment after missing the normal enquiry window. The grouping below is ours, made from what each decision says it was deciding.
| Question the tribunal decided | Cases | Taxpayer | HMRC | Partial |
|---|---|---|---|---|
| Did the work count as R&D? | 5 | 1 | 3 | 1 |
| Was it subsidised or contracted out because a client paid? | 3 | 3 | 0 | 0 |
| Penalty, deadline or eligibility condition | 3 | 2 | 1 | 0 |
- Did the work count as R&D? The tribunal looked at whether the project sought an advance in science or technology, and at the evidence for it. Hadee Engineering also turned partly on the subsidised and contracted-out rules.
- Was it subsidised or contracted out because a client paid? The R&D itself was not the main dispute. HMRC argued the SME scheme was barred because a client paid for the finished work.
- Penalty, deadline or eligibility condition The appeal was about something other than whether the work was R&D: a careless inaccuracy penalty (H&H), the going concern condition for RDEC (MW High Tech) and a discovery assessment made after the enquiry window closed (Realbuzz).
Reporting it accurately
What the data supports, and what it doesn't
Fair to say
- Every decided case in the tracker concerns the old SME scheme or old RDEC. We found no decision yet on a merged scheme or ERIS claim, which is what you'd expect: an appeal usually reaches a hearing years after the accounting period in dispute.
- Three First-tier Tribunal decisions (Quinn, 2021; Collins Construction and Stage One Creative Services, 2024) rejected HMRC's reading that a client paying for the finished work makes the R&D subsidised or contracted out.
- Where the question was whether the work counted as R&D at all, HMRC won 3 of 5, and the taxpayer won 1.
Not supported
- A tribunal success rate for taxpayers or HMRC. These 11 cases were chosen because they could be verified, not sampled from every R&D appeal, so the split can't stand for tribunal outcomes generally.
- That these cases settle how the merged scheme or ERIS will be applied. They were decided under earlier rules, and the contracted-out test changed from April 2024.
- That any case binds a later tribunal. First-tier Tribunal decisions don't, and each turns on its own facts.
Every case in one table
Citation, date, scheme, result and what each entry rests on
| Case | Citation | Decided | Scheme | Result | Source basis |
|---|---|---|---|---|---|
| AHK Recruitment Ltd v HMRC | [2020] UKFTT 232 (TC), Case No. TC07718 | 20 May 2020 | old SME scheme | HMRC | Full decision on BAILII |
| Hadee Engineering Co Ltd v HMRC | [2020] UKFTT 496 (TC), Case No. TC07969 (Appeal ref TC/2018/01111) | 13 October 2020 | old SME scheme | Partial | Full decision, copy hosted by a tax adviser |
| Grazer Learning Ltd v HMRC | [2021] UKFTT (TC) (Appeal ref TC/2019/06690) | 23 September 2021 | old SME scheme | HMRC | Full decision, copy hosted by a tax adviser |
| Quinn (London) Ltd v HMRC | [2021] UKFTT 437 (TC), Case No. TC08321 | 27 October 2021 | old SME scheme | Taxpayer | Professional case notes only |
| MW High Tech Projects UK Ltd v HMRC | Case No. TC09011 (also reported as [2023] UKFTT 1040 (TC)) | 5 December 2023 | old RDEC | HMRC | Professional case notes only |
| Flame Tree Publishing Ltd v HMRC | [2024] UKFTT 349 (TC), Case No. TC09149 | 25 April 2024 | old SME scheme | HMRC | Full decision on BAILII |
| Get Onbord Ltd (in liquidation) v HMRC | [2024] UKFTT 617 (TC), Case No. TC09238 | 9 July 2024 | old SME scheme | Taxpayer | Full decision on BAILII |
| Collins Construction Ltd v HMRC | [2024] UKFTT 951 (TC), Case No. TC09332 | 21 October 2024 | old SME scheme | Taxpayer | Full decision on BAILII |
| H&H Contract Scaffolding Ltd v HMRC | [2024] UKFTT 151 (TC) | 2024, exact date not confirmed | old SME scheme | Taxpayer | Professional case notes only |
| Stage One Creative Services Ltd v HMRC | [2024] UKFTT 1059 (TC), Case No. TC09358 | 2024, exact date not confirmed | old SME scheme | Taxpayer | Full decision on BAILII |
| Realbuzz Group Ltd v HMRC | [2025] UKFTT 493 (TC), Case No. TC09502 | 2025, exact date not confirmed | old SME scheme | Taxpayer | Professional case note; decision published by the National Archives |
Oldest first, with undated decisions at the end of their year. 3 decisions have no confirmed hand-down date (H&H Contract Scaffolding Ltd, Stage One Creative Services Ltd, Realbuzz Group Ltd), so the year shown comes from the neutral citation; the tracker explains each one. 3 entries rest on professional case notes because we couldn't find the full decision on a free public site. Check those against the decision itself before quoting its wording.
Downloads
The data as CSV and JSON
- rd-case-tracker.csv: one row per case, 11 rows, with sources, notes and outcome detail. Blank cells mean the detail couldn't be confirmed.
- rd-case-tracker.json: the tracker's own data file, including the methodology notes.
- Zenodo record: the snapshot deposited on 14 September 2026, behind the DOI.
The Zenodo snapshot and the current file hold the same 11 cases with the same citations, dates, schemes and outcomes. The edits made since are to wording: source labels, date notes and one summary. Both downloads here are built from the same file as the tracker page, so they always match what the page shows.
How to cite
Citing and reusing this dataset
The data is published under a Creative Commons Attribution 4.0 licence. You can quote it, republish it and build on it, commercially or not, as long as you credit it and link back. The DOI below points at the copy deposited on Zenodo on 14 September 2026. This page is the current version, and anything corrected since that deposit is listed in the methodology changelog.
- Reference list (APA style)
Parker, A. (2026). UK R&D Tax Relief First-tier Tribunal Case Tracker: Verified Tax Chamber Decisions [Data set]. Zenodo. https://doi.org/10.5281/zenodo.22753345
- In an article or report
Source: Established Finance, R&D Tribunal Case Tracker (establishedfinance.co.uk/rd-case-tracker/), compiled by Adam Parker.
- BibTeX
@misc{parker2026rdcases, author = {Parker, Adam}, title = {{UK R\&D Tax Relief First-tier Tribunal Case Tracker: Verified Tax Chamber Decisions}}, year = {2026}, publisher = {Zenodo}, doi = {10.5281/zenodo.22753345}, url = {https://doi.org/10.5281/zenodo.22753345}, note = {Dataset. Licensed CC BY 4.0} }
Cite the DOI above when you need a fixed version that won't change under you. 10.5281/zenodo.22753344 always resolves to the latest Zenodo version. Author ORCID: 0009-0008-0368-4408.
Who compiled it
Sources and method
The tracker was compiled by Adam Parker (ORCID 0009-0008-0368-4408) for Established Finance. Each case was checked against the published First-tier Tribunal decision (bailii.org and/or caselaw.nationalarchives.gov.uk where available) and cross-checked against at least one independent professional report (accountancy/tax law firm commentary). Cases that could not be independently corroborated were excluded. The full method is on the methodology page.
This is a summary of published decisions, not legal advice. If you're writing about a live dispute, the tracker's own limitations section and what happens in an HMRC enquiry give the context.
Checking a case, or spotted an error?
Email us with the case name and what you need. If a date, citation or outcome turns out to be wrong, the correction goes in the methodology changelog with the date it was made.