Writing the technical narrative for an R&D claim

Write to the test, not the product

The DSIT guidelines define the target in two sentences a narrative must hit. An advance means an increase in overall knowledge or capability in a field of science or technology, not just your own state of knowledge. And uncertainty exists when whether something is possible, or how to achieve it in practice, is not readily available or deducible by a competent professional working in the field.

Everything in a good narrative serves those two sentences. Product features, market context and effort belong in a pitch deck; they carry no weight here except as scenery. The narrative structure that works:

1. The field and the baseline. What could competent professionals in this field already do, with citations to what was readily available: published methods, standard tools, known limits. This is the sentence most claims skip and the first one a specialist reader looks for.
2. The advance sought. What increase in the field’s knowledge or capability the project aimed at, including an appreciable improvement to something existing. The guidelines define that as a genuine, non-trivial improvement a competent professional would acknowledge, not routine upgrading.
3. The uncertainties. Numbered, specific, technological: what was not known to be feasible, or not deducible as to method. Say why the baseline could not answer them.
4. The work. The systematic attempts: hypotheses, prototypes, tests, failures, redesigns. This is where the period’s actual activity lives, and where costs will be mapped.
5. The status. Resolved, partly resolved, abandoned. The guidelines are explicit that failure does not disqualify; unresolved uncertainty at period end simply defines next year’s claim.

The competent professional, on the record

HMRC’s compliance guidelines expect the qualifying judgement to come from a competent professional. That means someone knowledgeable about the relevant principles, aware of the current state of knowledge in the field as a whole, with accumulated experience and a successful track record. Having worked in the field, or an intelligent interest, is expressly not enough.

Two practical consequences. First, the narrative should say who the competent professionals were, in role terms, and ground its judgements in their assessment. Second, keep a written copy of the professional’s opinion with supporting reasoning; HMRC recommends exactly that, and warns that without it you may struggle to evidence the claim if the professional later becomes unavailable.

Draw the boundary honestly

The guidelines fix the qualifying window: R&D begins when work to resolve the uncertainty starts, and ends when the uncertainty is resolved or the work to resolve it stops. HMRC’s worked examples enforce the end of that window hard: in one, the uncertainty resolves on day 12 of a 20-day trial programme and the remaining 8 days of fine-tuning do not qualify.

So the narrative must place the boundary: which parts of the commercial project were inside the uncertainty window, and which, requirements gathering, routine build, polish, rollout, were outside it. A narrative that claims the whole commercial project is announcing that no boundary was drawn, and the costs inherit the problem. Qualifying indirect activities, the supporting work the guidelines allow, should be identified as such rather than smuggled in as direct work.

Sources

1. DSIT, Meaning of research and development for tax purposes: guidelines (2023), gov.uk
2. HMRC, GfC3 Part 3 (importance of a competent professional), gov.uk
3. HMRC, GfC3 Part 4 (how to identify qualifying R&D activities), gov.uk
4. HMRC, Additional information you must submit before you claim R&D tax relief, gov.uk