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
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