Tanglewood Care Services Limited v The Commissioners for HMRC
Decision date: 6 August 2026
Neutral citation: [2026] UKFTT 1137 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
Tanglewood appealed HMRC's Closure Notice disallowing an enhanced R&D claim of £880,286 for measures taken to manage Covid-19 in its care homes. The Tribunal found the activities formed a coordinated project but were operational/managerial responses using existing infection-control knowledge rather than efforts to achieve an advance in overall science or technology directed at resolving scientific or technological uncertainty. The appeal was dismissed.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
A project can be constituted under the relevant paragraph even without a formal written plan if there was a coordinated, structured programme of activity; however, to qualify as R&D under the Guidelines the project must seek an advance in overall knowledge or capability in a field of science or technology by resolving scientific or technological uncertainty, and claimants are aided by authoritative evidence from a competent professional as to the relevant field and baseline knowledge.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal indicated that “system uncertainty” can, in principle, encompass uncertainty about how known measures interact, and that advances in capability (not solely advances in scientific understanding) can qualify as R&D—provided they extend beyond an individual company’s operational improvement to an advance in overall knowledge or capability. It also noted that merely combining known measures does not automatically establish R&D.