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Q&A: The importance of full disclosure

09 June 2025 / Andy Grey , Stuart Rogers
Issue: 4988 / Categories: Comment & Analysis
Realbuzz Group - the importance of full disclosure in research and development claims


The recent First-tier Tribunal (FTT) decision in Realbuzz Group Ltd (TC9502) underlines the importance of providing full detailed disclosures to HMRC when making research and development (R&D) claims. It highlights the importance of disclosing the right information to HMRC in order to protect claimants from discovery assessments.

A high quality R&D report should provide sufficient disclosures and indicate that appropriate care has been taken both of which will significantly reduce HMRC’s ability to issue discovery assessments for earlier years.

What was the case about?

Most taxpayers are aware of HMRC’s standard powers that allow the department to open an enquiry into a return up to two years after the end of the accounting period even where HMRC has already made an R&D tax credit repayment. What many taxpayers are not so aware of is that HMRC has more extensive powers that in certain limited...

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