Is it R&D? HMRC’s definition (and how to prove it)

Here’s what counts, what doesn’t, and how to gather the right evidence without drowning in paperwork.

What HMRC means by “R&D”

A project qualifies for R&D tax purposes when it:

• Seeks an advance in science or technology,
• Tackles genuine scientific or technological uncertainties that a competent professional couldn’t easily resolve at the outset, and
• Follows a systematic approach (plan, build, test, learn).

Since April 2023, pure mathematics can also qualify where it delivers a scientific advance.

A 30-second self-check

Ask yourself these questions:

• Were we pushing beyond the known limits in our field?
• Did we face genuine technical unknowns, not just commercial hurdles?
• Would an expert say the solution wasn’t obvious at the start?
• Did we follow a structured process with experiments, prototypes, or trials?

If you’re saying “yes” to most of these, you’re likely in R&D territory.

Common examples that qualify

• Software & data: new algorithms, scaling beyond known limits, cryptography, unpredictable integrations.
• Engineering & manufacturing: new materials, experimental processes, meeting ambitious tolerance or emissions targets.
• Life sciences & food: new formulations, delivery methods, or processes where outcomes couldn’t be predicted without testing.

What doesn’t count

Routine debugging, cosmetic tweaks, straightforward replication of existing knowledge, standard configuration, or market research. These may sit within projects, but don’t qualify on their own.

Evidence HMRC expects

You don’t need a special system – just practical records that show:

• Project intent & baseline – problem statements, specs, architecture notes.
• Uncertainties & experiments – lab books, sprint tickets, test protocols/results, trial logs.
• Change history – version control, design iterations, JIRA boards.
• People & time – timesheets, contractor scopes, proof of PAYE for EPWs.
• Costs actually paid – payroll reports, invoices, payment proofs.
• Submission pack – narratives aligned to the Additional Information Form (AIF) and CT600 totals.

HMRC stresses practicality: enough to demonstrate the R&D and support your claim, without unnecessary paperwork.

Next steps

• Map your projects against the definition (advance + uncertainty + systematic work).
• Capture evidence as you go, don’t leave it until year-end.
• Sense-check borderline projects before drafting your AIF.

At The Tax Relief People, we help businesses assess eligibility, build a solid evidence trail, and draft enquiry-ready narratives.

Get in touch to see how we’d apply this to your sector and year-end.