UK R&D tax relief is about £7.5 billion in approved relief per year, per HMRC’s published annual statistics. Against that, a fragmented industry of specialist consultancies charges success fees in the 15–30% range to prepare the claims. Do the arithmetic: the consulting layer is roughly £1–2 billion of annual fees in the UK alone.
Poland’s B+R ulga (R&D relief) is a smaller market but structured similarly — a technical narrative, a qualifying-expenditure classification, a relief computation, and a filing.
Why the consulting layer exists
Preparing an R&D claim requires three distinct kinds of expertise:
- Knowing which of your development activities actually qualify under the BEIS guidelines (UK) or KAS interpretation (Poland).
- Writing the technical narrative in the specific rhetoric HMRC / KAS reviewers expect — arguing the scientific or technological uncertainty, the advance sought, the systematic investigation.
- Computing the relief correctly against the current rate structure, including the post-2024 UK merged-scheme transition.
Historically, none of this is work a general accountant did. It requires technical judgment plus domain vocabulary plus current-regulations awareness. So a consulting layer emerged: specialist firms charging success fees that capture a meaningful share of the relief they help secure.
Why the industry is now vulnerable
HMRC has sharpened scrutiny since 2024. A significant crackdown on aggressive claim-inflation by some consultancies has changed the HMRC posture. Claims now need inspectable, specific, defensible narratives. Generic claim-inflation language — which some consultancies still use — is now actively punished.
The rubric is public. BEIS guidelines, HMRC’s CIRD manual, and the published rate structures are all available. There is no secret here. What consultancies sell is discipline in applying the rubric, not access to hidden rules.
The per-claim work is highly structured. Ingest spend. Classify qualifying activity. Draft narrative. Compute relief. Package for filing. Each step is specific, repeatable, and rubric-bound — the shape of work that agent pipelines handle well.
What TaxAI does differently from a wrapper
A generic LLM will confidently write a claim narrative that HMRC will reject. The failure mode is specific: vague activity descriptions, unsupported claims of technological advance, mis-classification of routine work as R&D. Under the 2024+ HMRC scrutiny posture, those claims trigger enquiries and, increasingly, rejections.
TaxAI’s defensibility gate (agent/qa-defensibility) audits each claim specifically against current HMRC scrutiny standards. It flags:
- Activity descriptions too vague to survive an enquiry.
- Claimed technical advances not supported by the underlying spend data.
- Mis-application of the SME vs RDEC vs Merged Scheme rules for the claim year.
- Clients where the claim value is below the enquiry-cost-benefit threshold — HMRC will enquire, the defence cost will eat the relief.
The reasoning trail is inspectable. If HMRC opens an enquiry, the firm can produce the full basis for every classification and narrative claim, with the specific BEIS-guideline clauses each decision was made under.
The displacement arithmetic
A firm with a £500k annual R&D claim currently pays £75k–£150k in consulting fees. TaxAI licenses at a fraction of that, annualised. The firm owns the claim-preparation process, keeps its historical reasoning as a firm asset, and maintains the defensibility posture HMRC now demands.
For accounting firms, the calculus is different. They currently refer R&D work out to consultancies because they don’t have the specialist expertise. TaxAI gives them a product line to add without building that expertise from scratch — license the engine, apply accountancy judgment to the final review, bring the fee revenue back in-house.
"The R&D tax consulting industry exists because the work is specialised, structured, and rubric-bound. Which is exactly the shape of work that services-as-software disrupts."
TaxAI is planned for Q3–Q4 2026. Architecture inherits from GrantAI. Register pilot interest: enterprise@blackflake.com.
— Bartek Kubas · Founder-architect · Blackflake 15 July 2026 · Łódź, Poland