Realbuzz Group Limited appealed against a research & development (R&D) discovery assessment which ordered the charity to repay £335,452.57 plus interest. The original claim was made in an amended corporation tax return on 31 March 2021.

The HMRC officer originally investigating the claim was under the impression Realbuzz’s relief claim ‘was or had become excessive’ but could not determine whether the claims were innovative as they were for complex software developments.

Realbuzz’s claim was that HMRC was not entitled to raise a discovery assessment as ‘an officer could have been reasonably expected, on the basis of the information made available to him, to have been aware [of the excessive relief] before he ceased to be entitled to give notice of enquiry into the return for APE 2020’.

It