Skip to main content

UK: Providing scientific education through digital platform does not qualify for R&D tax relief (First-tier Tribunal decision)

Does not constitute scientific or technological advance

Share
january 8, 2026

The First Tier Tribunal held in M&C Educational Training Services Ltd (M&C) v HMRC that the taxpayer, a company that provided education and training in the field of metallurgy through an e-learning platform, was not entitled to research and development (R&D) tax relief.

The court found that although the taxpayer aimed to disseminate existing scientific knowledge in a technology-driven manner, it did not seek to advance existing scientific knowledge or capability in the field of metallurgy itself. Therefore, the project did not meet the requirements of the Department of Science, Innovation & Technology (DSIT) guidelines on the meaning of R&D for tax purposes.

Read a January 2026 report prepared by the KPMG member firm in the United Kingdom

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline