R&D enquiries – Where are we going?

We have felt for a number of years that research and development (R&D) was an area where HMRC had developed a blind spot. Claims were being submitted by R&D agents which did not immediately appear to qualify – yet they were then ‘accepted’ by HMRC and processed successfully.

These things were widely discussed by those tax specialists working within the sector. During an R&D consultative committee meeting in 2018 rogue R&D agents were discussed at length while senior members of the HMRC and the Treasury team listened in and the broader topic of agent regulation was debated. After that I anticipated an increase in HMRC R&D enquiry activity – but none followed.

Indeed R&D enquiries had already withered away from a reasonable number in around 2010 and by 2018 they were as rare as hen’s teeth. Quite how rare is hard to establish. I (and others)...