Rationale for Presenting a Simplified Project and R&D Claim

The purpose of outlining a straightforward project and corresponding R&D claim is to provide clarity in accordance with the UK’s Research and Development tax credit regulations as governed by HM Revenue & Customs (HMRC). It is acknowledged that neither legislation nor HMRC guidance is absolute; both require careful interpretation and application to the specific facts of each case.

The definition of Research and Development for tax purposes is inherently fact-sensitive and subject to interpretation based on the nature of the scientific or technological uncertainty being addressed. HMRC’s guidance (as set out in the Corporate Intangibles Research and Development Manual (CIRD), particularly CIRD81000 onwards) emphasises that qualifying R&D must seek to achieve an advance in science or technology by resolving such uncertainty through systematic investigation or analysis.

On this basis, and having regard to the facts as set out, the development of a biscuit with enhanced durability for dunking constitutes a qualifying activity under the UK R&D tax credit scheme, provided that it involves the resolution of scientific or technological uncertainty through systematic investigation, consistent with the criteria outlined in Sections 1044–1049 of the Corporation Tax Act 2010.