Written After the Event: What RDM Wines Teaches About Records

October 26, 2026

London · October 2026

A wine company has just lost an argument with HMRC, and the reason is worth any accountant's or finance director's time. It was not really about wine. It was about when the paperwork was written.

The case in brief

In RDM Wines Limited v The Commissioners for HMRC [2026] UKFTT 1348 (TC), the First-tier Tribunal dismissed the company's appeal against HMRC's rejection of its research and development tax relief claim for the period ending 31 October 2021. As Kevin Bailey sets out in his AccountingWEB write-up, the project was described as finding a way to put 187ml of wine into a 200ml can without losing flavour or shelf life. The company said it contracted the work to Riebeek Valley Wine Co. in South Africa, with staff in house tasting and analysing samples.

To support that, it offered three undated letters which, according to the report, appear to have been produced years after the events, plus oral evidence from a managing director with limited technical knowledge. HMRC pointed to an earlier case, Cry Me A River Limited v HMRC, on how memory gets reconstructed over time. The tribunal accepted that the letters were a product of memory and should be treated with the same caution as a witness's recollection.

What the tribunal said it would have expected to see is the useful part. AccountingWEB quotes the list: written instructions to the South African contractor, notes of the internal tasting meetings, emails or texts about the tests and results, feedback to the contractor, invoices for the work and samples, and a contract or at least some correspondence setting up the engagement. None of it was there. The £40,000 claimed for staff time had no timesheets behind it either. HMRC also produced emails from November 2022 that described RDM as a "new client", which did not sit well with work said to have been done a year earlier.

Why this matters beyond R&D

The lesson is not specific to R&D. A document written at the time carries weight because nobody knew then what it would later be needed for. A letter written years later, however honest, is shaped by what everyone now knows.

HMRC has said much the same in its own guidance. AccountingWEB notes that HMRC's Guidelines for Compliance, GfC3, published in 2023, recommends keeping relevant records from the start of an R&D project, and that the evidence it lists is mostly the kind that gets created naturally as work happens: designs, test results, photos, minutes and emails.

For accountants and FDs, the practical habits are fairly plain:

• Keep the email, invoice or meeting note as it was sent or written, not a tidied up copy made later.
• If something has to be corrected, save the correction as a new file and leave the earlier one alone.
• Record staff time when it is spent, not when a claim is being prepared.
• Keep everything for a project in one place from the first day, with a backup elsewhere.

None of this is tax advice. Check HMRC's guidance or speak to an adviser about your own position.

A timely reminder: 7 November

The same discipline applies to routine compliance. HMRC's Agent Update issue 148, published on 15 October, reminds agents that the second quarterly update deadline for Making Tax Digital for Income Tax is 7 November 2026. Clients with self-employment and property turnover above £50,000 should already be keeping digital records and using compatible software, and HMRC's advice is simply not to wait until deadline day.

Digital records sit on top of original ones. The invoices and statements behind the figures still need keeping, and the quarterly update is a natural moment to file them properly while they are fresh, rather than reconstructing them later.

Where Partisan fits, and where it does not

I work on business development and communications for Partisan. Partisan records a file's fingerprint without seeing or keeping the document, gives a dated receipt, and shows a file is unchanged since it was recorded.

In a case like RDM's, that would mean a contractor's instruction email, a tasting note or a timesheet could be recorded on the day it was made, and later shown to be the same file. If even one letter in it changes, the check fails.

The limits matter just as much. Partisan records exactly what it is given, accurate or not. A wrong figure recorded on Monday is still wrong on Friday, and a receipt does not make bad data good. Nor does it show when a document was first created, only that it has not changed since it was recorded. It cannot replace the records themselves. If nothing was written at the time, there is nothing to record.

What it can do is give a careful record keeper a simple, dated way to show that the file in front of HMRC is the one they kept.

If that is useful to your practice or finance team, you can read more at partisangateway.com or email me at contact@charlespycraft.co.uk.

Charles Pycraft