Hadee Engineering Ltd v HMRC

In Hadee Engineering Ltd v HMRC [2020] UKFTT 497 (TC) (10 December 2020) the FTT considered the company’s claims for research and development (R&D) relief under CTA 2009 s 1044.

The appellant was an engineering company which submitted claims for 2009 and 2010 for relief totalling approximately £300 000. The claims were formulated and submitted by a specialist R&D advisor but the advisor did not assist the company with HMRC’s enquiries. In support of the claims the company submitted a report compiled by the advisor which itemised the amounts claimed under seven separate projects. HMRC concluded that the company had not met the burden of proof that any of the expenditure had satisfied the tests to be classed as R&D. The company appealed.

The FTT considered that the company had to demonstrate that there was a clear methodology behind its activities...