M-Sport Wheels Limited v The Commissioners for HMRC
Decision date: 30 June 2026
Neutral citation: [2026] UKFTT 977 (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
M‑Sport appealed HMRC’s refusal of R&D claims for 2020 and 2021 but encountered prolonged witness‑evidence problems, sought and was refused extensions, and then withdrew the appeal shortly before the hearing. HMRC applied for costs under Rule 10(1)(b) alleging unreasonable conduct; the Tribunal held HMRC had not proved the Appellant’s conduct fell outside the range of reasonable conduct and refused the costs application.
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
Reasonableness for Rule 10(1)(b) is assessed against what was known at the time and allows for a range of reasonable conduct (including some omissions); conduct must fall outside that range to justify a costs award. Where a withdrawal is late, the tribunal should ask why the party withdrew, whether it could have withdrawn earlier, and whether it was unreasonable not to do so (applicant for costs bears the burden of proof).
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 observed that repeated procedural failings can amount to imperfect case management without reaching the threshold of unreasonable conduct under Rule 10, and that costs incurred after a party was aware withdrawal was likely are a relevant factor in the discretionary exercise whether to award costs.