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.

Founded by Adam Parker No obligation to talk it through

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

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 decidedCasesTaxpayerHMRCPartial
Did the work count as R&D?5131
Was it subsidised or contracted out because a client paid?3300
Penalty, deadline or eligibility condition3210

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

CaseCitationDecidedSchemeResultSource 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

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.

Adam Parker

Adam Parker

Founder of Muswell Rose Consulting Ltd, which trades as Established Finance · former Managing Director of Penny, an invoice finance business, working in mortgages, commercial finance and fintech lending since 2010 (career history).

Figures checked: