The Background: An R&D Claim That Never Reached HMRC
- Adam Colsen
- Aug 12
- 3 min read
James Mackie Wholesale Ltd is no small corner-shop greengrocer. The Glasgow-based company turns over around £25 million a year supplying wholesale fruit and vegetables — a scale that demands complex cold-chain logistics.
The project at the heart of the controversy was an attempt to develop a notable refrigeration improvement designed to extend the shelf life of perishable goods.
ZLX Technology was engaged to assess and prepare an R&D claim for this work. According to ZLX, the claim was at stage 2 of their detailed 8-stage process — meaning it had not yet been finalised, let alone submitted to HMRC.
In other words: the claim was not filed, not approved, and not paid out by HMRC. The “narrative” stage — compiling the evidence and articulating the technical advancement — was still in progress.
The Commercial Dispute
The relationship between ZLX and James Mackie broke down before the R&D process was completed. ZLX argued that under its terms and conditions, it was entitled to payment for work already completed — even if the claim had not been submitted. James Mackie disagreed.
The dispute went to court. ZLX lost the case and chose not to appeal.
That should have been the end of it. But it wasn’t.
How the Narrative Changed Online
Enter Dan Neidle of Tax Policy Associates. In his write-up, he characterised James Mackie Wholesale as “just a fruit and veg company” and portrayed the claim as nothing more than a fridge bought off the shelf in 15 minutes — implying there could be no R&D involved.
This framing — catchy, dismissive, and easy to share — bore little resemblance to the project’s scope as described by ZLX. According to Steve McCallion, this was not about picking a fridge from a catalogue, but about engineering a refrigeration solution with materially improved performance in food preservation.
Yet, once the “fridge in 15 minutes” story took hold, the online reaction became a feeding frenzy. Rosser and Neidle amplified the narrative across social media, using it as further ammunition in their broader campaign against what they see as R&D tax abuse.
The Man in the Crosshairs
Steve McCallion is not a fly-by-night tax scheme promoter. He’s a qualified engineer with 35 years of experience and the owner of robotics, engineering, and food processing businesses.
For months, McCallion has been subjected to online abuse, ridicule, and accusations — despite the fact that the disputed claim never reached HMRC. In a recent 15-minute podcast interview, he described the experience and criticised what he sees as a pre-determined narrative driven by campaigners before full facts are established.
This is not the first time Neidle and Rosser’s online campaigns have been accused of oversimplifying — or misrepresenting — technical realities. Others in the R&D sector, including Green Jellyfish, have reported similar experiences of reputational damage without due process.
A Familiar Pattern
The case raises uncomfortable questions:
Selective Framing – Does reducing a complex engineering project to “a fridge bought in 15 minutes” serve truth, or just engagement metrics?
Due Process vs Trial by Social Media – Should individuals and companies be publicly accused before evidence is complete?
Collateral Damage – How many legitimate R&D providers have been tarnished by the same broad brush used to target bad actors?
What’s clear is that the ZLX/JMWL dispute began as a straightforward commercial disagreement, but was reframed online into an R&D scandal that never actually happened.
The Takeaway
The ZLX episode is a reminder that in the age of online outrage, the truth can be outpaced — and overshadowed — by a convenient narrative.
For those in specialist sectors like R&D tax credits, refrigeration engineering, or robotics, it’s a cautionary tale: once your story is simplified for clicks, regaining the nuance can be nearly impossible.
In McCallion’s own words, “The narrative was decided before the facts were in.”
Listening to the full podcast and reading both sides before forming an opinion is not just fair — it’s essential.
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