RDM Wines Limited v The Commissioners for HMRC
Decision date: 24 September 2026
Neutral citation: [2026] UKFTT 1348 (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
RDM Wines appealed HMRC’s disallowance of an R&D tax relief claim for the period to 31 October 2021, relying on contractor Riebeek’s canning work. The Tribunal found RDM had not proved, on the balance of probabilities, a qualifying R&D project that sought an advance in science or technology beyond industry knowledge and placed little weight on late-produced letters and reconstructed evidence. The appeal was dismissed; quantum was not considered.
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: high
The Tribunal treated contemporaneous documentary evidence (or reliable contemporaneous records) as critical to proving an R&D project’s existence, scope and chronology; reconstructed or late-generated statements produced for litigation carry little weight if inconsistent with contemporaneous materials. RDM failed to show an advance beyond what the Winemaker’s Guide and other industry knowledge made readily deducible, so the claimed activities did not meet the Guidelines’ project/advance requirements.
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: high
The Tribunal reiterated caution about the reliability of witness memory and the limited weight to be given to accounts reconstructed during litigation preparation. It also noted that, when assessing whether an advance was achieved, a “competent professional” should demonstrate appropriate qualifications, experience and up-to-date knowledge.