Our Approach to Legislative Interpretation – A perspective from the Knight R&D team

At Knight R&D, legislative interpretation is not something that happens at the end of the process…it is where every engagement begins.

As a team, we spend as much time understanding the legislation as we do understanding our clients’ projects. R&D tax relief sits within a tightly defined statutory framework, and our responsibility is to apply that framework carefully, consistently, and objectively.

We start with the legislation, not the outcome

Our starting point is always the legislation itself.

Before considering value, percentages, or costs, we ask:

• What does the legislation actually require?
• What is the technological baseline?
• Where is the uncertainty?
• Has an advance genuinely been sought?

Only once that framework is established do we assess whether activity falls within scope. This prevents optimism from distorting analysis and ensures that conclusions are grounded in statutory reality rather than commercial pressure.

Technical and tax: Interpreted together

Legislative interpretation in R&D cannot be done purely from a tax perspective.

Equally, it cannot be done purely from an engineering perspective.

Our team is trained to understand:

• The statutory framework
• HMRC guidance
• The technical realities of project delivery
• The difference between complexity and uncertainty

This integrated approach allows us to interpret legislation in context, not in isolation.

We apply a conservative standard of evidence

Interpretation is not about stretching definitions.

In fact, our philosophy is the opposite.

We apply a disciplined evidential standard and ask whether we would be comfortable defending the position under scrutiny. If the technological uncertainty cannot be clearly articulated, it does not belong in the claim.

That discipline protects our clients long term.

We recognise grey areas and treat them carefully

We don’t treat projects as simply “qualifying” or “non-qualifying” in their entirety.

Instead of making an all or nothing judgement, we break the project down into its individual components and assess each element carefully, based on the legislation.

That means:

• Separating routine engineering from genuine uncertainty
• Allocating costs carefully
• Avoiding narrative exaggeration
• Ensuring the claim reflects technical reality

Precision builds credibility. Credibility withstands scrutiny.

Interpretation as a team discipline

From day one, every member of the Knight team is trained to understand the legislation end to end…financial, technical, and evidential. This consistency ensures that our approach is applied uniformly across every engagement.

It also means that clients are not reliant on a single voice. Our methodology is embedded across the team.

Why This Matters Now

With increased HMRC scrutiny and legislative reform, interpretation has never been more important.

Generic narratives and high-level descriptions are no longer sufficient. Claims must demonstrate clarity of thought and depth of technical understanding.

A well-interpreted claim is not only more defensible, it is more accurate.

The Knight Philosophy

We believe that clarity is more valuable than optimism.

Our role is not to maximise numbers at the expense of risk. It is to interpret legislation carefully, identify genuine qualifying activity, and prepare submissions that stand up to scrutiny.

That approach may require more time. It requires deeper technical engagement. It demands intellectual discipline.

But it is what underpins defensible outcomes and long-term client relationships.