A company claiming research and development relief failed to show that the tests in the Department for Business, Innovation and Skills guidelines were met and failed to prove that the sums claimed were spent on the project.  

The appellant, a publishing company, filed an amended corporation tax (CT) return for the accounting period ended 30 June 2018. The appellant originally published books in bound paper form, including encyclopaedias and music guides, and the texts of those publications were archived on CDs and DVDs. With the advent of the internet, the market for those books declined, and the appellant began to sell smaller and more affordable publications.  

After considerable work, the books in the appellant’s digital archive were made available to customers as searchable resources which had been ‘curated’ or organised intelligently by the appellant’s staff. The process finished in mid-2019. By the CT