Substantiating R&D Tax Offset Claims: What Evidence the ATO Requires (And What Actually Stands Up in Court)

You’ve invested heavily in research and development. Your team has solved genuine technical problems. You’ve claimed the R&D tax offset.

Then the ATO comes knocking.

They want time sheets. Detailed logs. Contemporaneous records showing who did what, when, for how long. If you can’t produce them, they disallow the claim.

But here’s what most businesses don’t realise: the ATO’s position on what evidence is “essential” isn’t actually what the law says. And it’s not what courts consistently apply when these disputes land in front of them.

The gap between what the ATO asks for and what actually holds up under scrutiny creates both risk and opportunity. If you understand that gap, you can navigate it.

What the R&D Tax Incentive Actually Covers

The research and development tax incentive exists to encourage Australian companies to engage in genuine R&D by providing tax offsets for eligible expenditure.

But “eligible” has a specific meaning. Not every innovation qualifies. Not every experiment counts.

An eligible R&D entity (predominantly Australian corporations) can deduct expenditure incurred during an income year to the extent that expenditure relates to R&D activities. These activities must be either “core R&D activities” or “supporting R&D activities”.

Core R&D Activities: The Four-Part Test

Core R&D activities are experimental activities. The word “experimental” matters. You’re not just building something new, you’re testing a hypothesis where the outcome is genuinely uncertain.

The activity must meet four criteria:

• The outcome cannot be known or determined in advance based on current knowledge, information, or experience. If you’re applying known techniques to solve a problem with a predictable result, it’s not core R&D.
• The outcome can only be determined by applying principles of established science. You’re using systematic methodology, not trial and error or guesswork.
• The progression of work follows scientific method: hypothesis to experiment, to observation and evaluation, leading to logical conclusions. There’s a structured approach.
• The purpose is generating new knowledge. You’re not just applying existing knowledge in a new context. You’re creating knowledge that didn’t exist before.

This is a high bar. Many activities that feel innovative don’t clear it.

Some expenditures explicitly excluded from core R&D include market research, management studies, efficiency surveys, developing computer software (unless it involves eligible R&D itself), and research in social sciences, arts, or humanities.

If you’re testing whether consumers will buy your new product, that’s not R&D. If you’re refining your supply chain processes, that’s not R&D. If you’re building an app using standard coding techniques, that’s not R&D.

Supporting R&D Activities: The Connection Test

Supporting R&D activities are activities directly related to core R&D activities. The key word is “directly”.

What counts as supporting is circumstance-dependent. You must prove a genuine connection between the supporting activity and the core R&D. The supporting activity must be undertaken for the dominant purpose of supporting the core activity.

Examples of what typically won’t qualify as supporting R&D: conducting a literature review or internet search to identify a market niche for a new product, cleaning or maintaining equipment that wasn’t used in an experiment, or decommissioning equipment after R&D concludes.

The connection must be tight. Ancillary activities that happen in the same business at the same time aren’t automatically supporting R&D just because core R&D is also happening.

What the Law Actually Says About Substantiation

The R&D tax incentive operates on self-assessment. You assess whether your activities meet the criteria, claim the offset, and take responsibility for ensuring you meet the requirements.

When it comes to record keeping, the legislation is surprisingly broad.

The Income Tax Assessment Act 1936 provides a general description of records that must be kept: “any documents that are relevant for the purposes of ascertaining income and expenditure.”

That’s it. No specific mention of time sheets. No requirement for contemporaneous logs. No prescribed format.

This broad legislative framework creates a problem: it leaves enormous interpretive space for the ATO to define what they consider adequate substantiation.

And the ATO has filled that space with very specific requirements.

The ATO’s Position: Specific Documents Are Essential

In practice, the ATO requires records sufficient to verify three things:

So far, reasonable. But the ATO goes further, specifying documentary evidence of:

Time records: The amount of time spent on eligible R&D projects by employees, including who conducted the activities and time spent by each staff member. The ATO historically expects work diaries, time sheets, and activity logs showing contemporaneous tracking of R&D versus non-R&D time.

Apportionment documentation: Documents showing how you apportioned expenditure between eligible core R&D activities, supporting R&D activities, and other non-R&D activities. The apportionment method must be reasonable for the type of expenditure, and the ATO typically expects you to use more than one method depending on the expenditure type.

These requirements reflect a relatively narrow interpretation of the legislation. They assume a level of granular contemporaneous record-keeping that many modern businesses simply don’t maintain.

Your software developers don’t fill out time sheets allocating hours between “eligible core R&D on Algorithm X” and “standard development work on Feature Y”. Your research scientists don’t log daily hours against specific experimental hypotheses.

Many businesses operate in agile environments where work isn’t neatly categorised in real time. Teams move fluidly between projects. Activities blend.

The ATO’s position creates a mismatch between how innovative businesses actually operate and what the tax office expects to see when reviewing a claim.

What Courts Actually Require: Documentary Evidence Is Not Essential

Here’s where it gets interesting.

When disallowed R&D tax offset claims are challenged before the Administrative Appeals Tribunal or the Federal Court, the approach differs markedly from the ATO’s position.

Courts consistently hold that documentary evidence is helpful, but not essential, to validate the existence of eligible R&D activity.

The leading case is Commissioner of Taxation v Bogiatto [2020] FCA 1139. The Federal Court stated:

“It is a misconception implicit in some of the Commissioner’s submissions that documentary evidence is the only kind of evidence which can substantiate the relevant taxable facts.

A taxpayer might have inadequate records yet establish to the satisfaction of the ATO or the Tribunal on review, or a Court for some other purpose, that R&D activities were carried out and that relevant expenditure was incurred.”

Read that again. “A taxpayer might have inadequate records” yet still establish eligibility.

This isn’t a fringe view. It’s consistent with how civil litigation operates across Australian tax law. The standard of proof is balance of probabilities. You need to convince the decision-maker it’s more likely than not that your activities were genuine R&D and that you incurred the expenditure you claim.

Documentary evidence is one way to meet that standard. It’s often the best way. But it’s not the only way.

Alternative Forms of Evidence the Courts Accept

When a company’s contemporaneous records are inadequate or incomplete, eligibility can be established through:

Witness statements and statutory declarations: Evidence from the people who actually conducted the R&D activities describing what they did, why, how it met the statutory tests, and what technical uncertainties they were resolving.

Oral testimony: Where witnesses give evidence in a hearing, subject to cross-examination. If their testimony is credible and consistent, it can substantiate activities even without supporting documents.

Expert evidence: Independent experts can assess whether the activities described meet the statutory definition of core R&D, whether the scientific method was applied, whether genuine technical uncertainty existed.

Reconstructed records: Even if contemporaneous time sheets don’t exist, you can reconstruct approximate allocations using project plans, meeting notes, email threads, code repositories, lab notebooks, purchase orders for materials used in experiments, and other indirect evidence.

Circumstantial evidence: Physical outputs (prototypes, test results, failed experiments, iterations), the qualifications of staff involved, the fact that solutions weren’t obvious or available in the market, third-party validation (grants, patents, publications).

The ATO is required to consider all evidence on the balance of probabilities. They can’t simply dismiss a claim because time sheets are missing.

Importantly though, the evidence, whether documentary or otherwise, must be robust. Courts expect substance. Vague assertions won’t cut it. Self-serving statements without corroboration won’t suffice.

But if you can piece together a credible narrative using multiple forms of evidence that collectively demonstrate genuine R&D occurred and genuine expenditure was incurred, you can succeed even without the ATO’s preferred documents.

The Practical Gap: What This Means for Your Claim

The gap between the ATO’s position and what courts accept creates both risk and strategic opportunity.

Risk: ATO Disallowance Based on Missing Records

If you lodge an R&D claim and the ATO reviews it (which they increasingly do for larger claims or claims in certain industries), they will ask for specific documents.

If you can’t produce detailed time sheets and contemporaneous apportionment records, the ATO will often disallow the claim or substantially reduce it. They’ll take the position that you haven’t adequately substantiated the expenditure.

You’ll receive an amended assessment. If you don’t challenge it, that’s the end of the matter. You lose the offset.

Many businesses accept this outcome, assuming the ATO’s view is final. They believe that without the specific documents the ATO requested, they have no case.

That assumption is wrong.

Opportunity: Building an Alternative Case

If you have genuine R&D activities and genuine expenditure, but incomplete records, you can challenge the ATO’s decision.

This requires understanding that the dispute has shifted from administration (what the ATO wants) to litigation (what you can prove).

In the Tribunal or Court, the question isn’t “Did you comply with the ATO’s internal guidelines?” The question is “On the balance of probabilities, did you conduct eligible R&D activities and incur the claimed expenditure?”

Building an alternative case means:

Gathering all available evidence, even if it’s not what the ATO initially requested. Project documentation, design specifications, test results, emails discussing technical challenges, invoices for specialist equipment, staff CVs showing relevant expertise.

Preparing detailed witness evidence from the people who conducted the work. Get them to describe the hypothesis, the experiments, the uncertainties, the methodology, the outcomes. Make it specific and technical.

Reconstructing time and cost allocations using reasonable approximations based on project plans, team structures, salary records, and the nature of the work.

Engaging expert witnesses if needed to validate that the activities met the statutory tests for R&D and that the apportionment methods used were reasonable.

This approach works. Businesses win these cases, even without perfect contemporaneous records, when the underlying substance is strong and the alternative evidence is credible.

When Perfect Records Still Matter

None of this means you should ignore record-keeping.

Contemporaneous, detailed records remain your strongest defence. If you can hand the ATO time sheets, project logs, and clear apportionment documentation, your claim is far more likely to be accepted without challenge.

Alternative evidence strategies are more expensive. You’re fighting a dispute rather than passing a review. You’re engaging lawyers and experts. You’re investing time preparing statements and reconstructing information.

If you’re planning future R&D claims, implement proper record-keeping now. Require staff working on R&D projects to maintain basic logs. Document the experimental process. Keep meeting notes. Record hypotheses, tests, results, iterations.

But if the R&D has already happened, the records are incomplete, and you’re facing disallowance, don’t assume you’ve lost. The law gives you pathways the ATO’s guidelines don’t acknowledge.

Common Substantiation Challenges and How to Address Them

Let’s get practical. Here are the most common substantiation problems businesses face and how courts have approached them.

Challenge 1: Staff Worked on Both R&D and Non-R&D Activities

Your software team spent some time developing a genuinely innovative algorithm (core R&D) and some time building standard user interface features (not R&D). They didn’t track time separately.

The ATO wants time sheets. You don’t have them.

How to substantiate: Reconstruct a reasonable allocation. Use project management tools (Jira, Asana) to estimate time spent on different tasks. Use code commits and version control history to show when R&D components were being developed. Get team leads to provide estimates based on project phases and team allocation. Document your methodology clearly.

If the methodology is reasonable and the estimates are conservative, courts generally accept them. The ATO may challenge the percentages, but the claim isn’t automatically doomed.

Challenge 2: Apportionment Across Multiple Projects

Your R&D entity ran three projects. One was clearly core R&D. One was clearly not. One was mixed.

You claimed costs for salaries, overheads, materials. The ATO says your apportionment is arbitrary.

How to substantiate: Show the apportionment method suits the expenditure type. For direct costs (materials used in experiments), allocate based on actual usage tracked in purchase orders or lab records. For salary costs, allocate based on project time (reconstructed if necessary). For overheads (rent, utilities), allocate based on a reasonable proxy like floor space or headcount dedicated to R&D.

Use more than one method. Courts accept that different cost types require different apportionment approaches. What matters is that each method is logical and defensible.

Challenge 3: Outcome Was Partially Predictable

You developed a new manufacturing process. Some technical uncertainties existed, but the overall outcome (a more efficient process) was the intended goal from the start.

The ATO argues the outcome was predictable, therefore not core R&D.

How to substantiate: Focus on the specific technical uncertainties, not the commercial goal. Every R&D project has a desired outcome. The test isn’t whether you hoped to succeed. It’s whether the path to success involved resolving genuine technical unknowns.

Provide evidence of the specific hypotheses tested, alternative approaches tried, failed experiments, unexpected results that required new approaches. Show that competent professionals in the field couldn’t have predicted the solution method in advance.

Expert evidence can be powerful here. An independent expert can assess whether the technical challenges required genuine experimentation or were routine applications of known techniques.

Challenge 4: Documentation Was Created After the Fact

You didn’t maintain detailed contemporaneous records. After the ATO raised concerns, you prepared detailed reports describing the R&D activities.

The ATO dismisses these as self-serving reconstructions.

How to substantiate: Don’t rely solely on after-the-fact reports. Corroborate them with whatever contemporaneous evidence exists, even if it’s indirect. Email threads discussing technical problems. Meeting invites and agendas. Purchase orders for specialist equipment or materials. Drafts and iterations of designs or code.

Then supplement with credible witness evidence. People who were actually there, describing what they did. If their oral testimony is tested under cross-examination and holds up, it carries weight even if the contemporaneous paper trail is thin.

Courts distinguish between genuine reconstruction (using reliable memory and available evidence to accurately describe what happened) and fabrication (inventing a narrative to fit the claim). If your reconstructed evidence aligns with whatever contemporaneous evidence does exist and is internally consistent, it can succeed.

How Apportionment Actually Works in Practice

Apportionment is one of the most contested aspects of R&D claims. You need to separate eligible R&D expenditure from non-eligible expenditure.

The ATO’s view is that apportionment must be precise, contemporaneous, and supported by detailed records.

The reality is messier.

The Core Principle: Reasonable and Defensible

Courts don’t require perfection. They require a method that is:

“Reasonable” doesn’t mean arbitrary. You can’t simply claim 50% of all costs because it feels about right. But you also don’t need minute-by-minute time tracking if you can demonstrate a logical basis for your allocation.

Different Methods for Different Costs

A single apportionment method across all expenditure types is rarely appropriate. Courts expect you to tailor the method to the cost.

Direct salary costs: Apportion based on time spent on R&D activities. If you have time sheets, use them. If you don’t, reconstruct estimates using project records, team allocation, and witness evidence. Document your assumptions.

Materials and consumables: Apportion based on actual usage in R&D activities. Purchase orders, inventory records, lab notebooks showing materials consumed in experiments.

Equipment and depreciation: If equipment is used exclusively for R&D, claim 100%. If used for both R&D and non-R&D, apportion based on usage (tracked if possible, estimated reasonably if not). Equipment used for a discrete R&D project then repurposed is apportioned based on time periods.

Overheads (rent, utilities, general admin): Apportion based on a reasonable proxy. Common approaches include percentage of floor space dedicated to R&D, percentage of headcount engaged in R&D, or percentage of total project time spent on R&D. Pick a method that makes sense for your business and apply it consistently.

Contractors and consultants: If engaged specifically for R&D, claim the full cost. If engaged for mixed purposes, apportion based on their actual time on R&D (invoices, statements of work, timesheets if available).

The key is showing you’ve thought it through. Different expenditure types have different allocation logics. Use the right logic for each type.

Document Your Methodology

Even if your underlying records are imperfect, document how you apportioned costs and why.

Prepare a note (contemporaneous if possible, reconstructed if necessary) explaining:

• The categories of expenditure claimed
• The apportionment method used for each category
• Why that method is reasonable
• The evidence supporting the allocation percentages
• Any assumptions made and why they’re conservative

When the ATO challenges your apportionment, you’re defending the reasonableness of your methodology, not claiming it’s perfectly precise. If you can show you applied logical, consistent methods and your estimates are credible, you’re in strong territory.

What to Do If You’re Facing an ATO Review or Disallowance

You’ve lodged your R&D claim. The ATO has written requesting further information or has issued a notice disallowing the claim.

What now?

Step 1: Understand What the ATO Is Actually Challenging

Read the ATO’s correspondence carefully. Are they questioning:

• Whether the activities meet the statutory definition of R&D?
• The quantum of expenditure claimed?
• The apportionment methodology?
• The lack of specific documentation?

Different challenges require different responses. If the ATO is challenging the nature of the activities, you need evidence (witness statements, expert opinion) demonstrating genuine technical uncertainty and scientific method. If they’re challenging quantum or apportionment, you need to reconstruct cost allocations and explain your methodology.

Don’t respond generically. Address the specific concerns raised.

Step 2: Gather All Available Evidence

Collect everything, even if it wasn’t created as formal R&D documentation:

• Project plans, technical specifications, design documents
• Meeting notes, email threads discussing technical challenges
• Code repositories, version control history, lab notebooks
• Test results, prototypes, iterations, failed experiments
• Invoices, purchase orders, employment records
• Any contemporaneous documents showing the nature and timing of activities

Then identify gaps. What evidence the ATO ideally wants but you don’t have?

Step 3: Assess Whether Alternative Evidence Can Fill the Gaps

For each gap, consider:

• Can you reconstruct the information using other sources?
• Can witnesses credibly speak to what happened?
• Would expert evidence help establish that activities were genuine R&D?

Be realistic. If you claimed costs for activities that genuinely weren’t R&D, no amount of alternative evidence will save the claim. But if the activities were genuine R&D and the expenditure was real, alternative evidence pathways exist.

Step 4: Decide Whether to Challenge or Concede

Challenging an ATO decision means objecting to the amended assessment, potentially proceeding to the Tribunal or Court. It costs money and takes time.

The decision calculus:

• Size of claim: Is the disallowed amount material enough to justify the cost of dispute?
• Strength of underlying case: Were the activities genuinely R&D? Is the expenditure real and reasonably apportioned?
• Quality of available evidence: Even if imperfect, is there enough to build a credible case?
• Risk tolerance: Are you prepared for the time and attention a dispute requires?

Get specialist advice before making this call. A litigator experienced in R&D disputes can assess your prospects realistically and help you weigh the costs and benefits.

Step 5: Engage Specialists Early

If you’re going to challenge, engage specialists early in the process, ideally before you respond to the ATO’s initial queries.

Why early? Because how you frame your initial response can determine the trajectory of the dispute. If you respond defensively, acknowledge weaknesses, or fail to lead with your strongest evidence, you set a poor foundation.

A specialist can help you:

• Identify and lead with your strongest evidence
• Frame the dispute around legal tests the ATO must apply
• Prepare robust witness statements and affidavits
• Engage appropriate experts if needed
• Assess prospects and settlement opportunities

Tax litigation isn’t the same as tax compliance. The skills required are different. You need someone who understands both the substantive R&D law and how evidence is tested in disputes.

Where Businesses Go Wrong (and How to Avoid It)

Let’s talk about the common mistakes that turn defensible R&D claims into losing disputes.

Mistake 1: Assuming ATO Guidelines Are Legal Requirements

The ATO publishes guides, rulings, and factsheets explaining their interpretation of R&D requirements. These are helpful. But they’re not law.

When businesses assume ATO guidelines are binding legal requirements, they concede claims they could defend. “The ATO says we need time sheets, we don’t have time sheets, therefore we have no case.”

That’s not how it works. The legislation sets the requirements. Case law interprets the legislation. ATO guidelines reflect the ATO’s view, which you can challenge.

If your activities meet the statutory tests and you can substantiate them on the balance of probabilities (even without the ATO’s preferred documents), you have a case.

Mistake 2: Providing Vague or Inconsistent Evidence

When contemporaneous records are thin, businesses sometimes respond with high-level summaries or vague descriptions.

“Our team worked on innovative solutions.” “We conducted experiments to solve technical problems.” “We allocated approximately 60% of costs to R&D.”

This doesn’t work. If you’re relying on reconstructed or alternative evidence, it needs to be detailed, specific, and consistent.

Who worked on what? What specific technical uncertainties existed? What experiments were conducted? What were the hypotheses? What methods were used? What were the results? Why couldn’t the outcome have been predicted in advance?

Vague evidence invites the ATO to dismiss your claim as unsubstantiated. Detailed, specific evidence forces them to engage with the substance.

Mistake 3: Claiming Non-R&D Activities as R&D

Some businesses adopt a broad interpretation of what counts as R&D, claiming activities that clearly don’t meet the statutory tests.

Standard product development. Routine engineering. Implementing known solutions. Management or administrative work.

These don’t become R&D just because they’re innovative or difficult. The statutory tests are specific. If you claim ineligible activities, you undermine your entire claim, including the genuinely eligible components.

Be disciplined. Only claim activities that meet the four-part test for core R&D or the direct relationship test for supporting activities. Exclude everything else, even if it feels innovative.

Mistake 4: Reconstructing Evidence Without Corroboration

After the fact, you prepare a detailed report describing R&D activities. It’s well-written and comprehensive. But it’s not corroborated by any contemporaneous evidence or independent witnesses.

The ATO will dismiss this as self-serving. And in a dispute, it won’t carry much weight on its own.

Reconstructed evidence works when it’s supported by:

• Whatever contemporaneous evidence does exist (even if indirect)
• Multiple independent witnesses who can corroborate the narrative
• Expert validation that the described activities meet R&D tests
• Internal consistency (the story makes sense and aligns with what can be verified)

Uncorroborated reconstructions fail.

Mistake 5: Failing to Act on Disallowance

You receive an amended assessment disallowing your R&D claim. You’re disappointed but assume there’s nothing you can do.

You don’t lodge an objection. The time limit expires. The disallowance becomes final.

This is a costly mistake if you had a defensible case. Once the objection period expires (typically 60 days for small businesses, varies for larger entities), your options are extremely limited.

If you believe your claim was legitimate, act. Lodge an objection. Seek advice. Understand your prospects before you concede.

The Intersection of Record-Keeping and Legal Strategy

Here’s the reality: the best legal strategy is not needing one.

If you maintain robust contemporaneous records of your R&D activities from the start, you dramatically reduce the risk of ATO challenge and the cost of defending your claim if challenge occurs.

But “robust contemporaneous records” doesn’t mean lawyers should be drafting your lab notebooks.

What Good R&D Record-Keeping Looks Like

Project documentation: Clear descriptions of each R&D project, the technical challenges being addressed, the hypotheses being tested, the methodology being used. This doesn’t need to be formal. Project plans, design specs, research proposals all serve this purpose.

Activity logs: Basic records of who is working on what and approximately how much time they’re spending on R&D versus other activities. This can be as simple as periodic team updates or project status reports.

Technical records: Lab notebooks, test results, experiment logs, code commits, design iterations. Whatever your scientists, engineers, or developers naturally create as they work. Don’t create new bureaucracy, just retain what’s already being generated.

Expenditure records: Invoices, payroll records, purchase orders clearly linked to R&D projects. When you buy specialist equipment or materials for an experiment, note the project in the purchase documentation.

Apportionment notes: Periodic notes explaining how you’re allocating costs between R&D and non-R&D. Doesn’t need to be daily. Monthly or quarterly snapshots showing your allocation logic.

Meeting notes and emails: Teams working on R&D naturally discuss technical challenges, experimental approaches, unexpected results, pivots in methodology. Don’t discard these. They’re contemporaneous evidence of the R&D process.

None of this requires a dedicated compliance function. It’s about being intentional with information you’re already creating.

When to Bring in Legal Support

Engage legal support in two scenarios:

Scenario 1: You’re planning significant R&D claims and want to get record-keeping right from the start. A litigation-focused firm can explain what evidence carries weight in disputes, what gaps matter, and what overkill looks like. You design your documentation approach with defence in mind.

Scenario 2: You’re facing ATO challenge or disallowance. Once you’re in dispute, you need specialists who understand both the substantive R&D law and how to build and present evidence in contested matters.

Don’t wait until you’ve exhausted internal dispute resolution before seeking advice. Bring specialists in early, when strategic choices still exist.

The Bottom Line: Substance Over Form

The R&D tax incentive rewards genuine innovation and risk-taking. The substantiation requirements exist to prevent abuse, not to create impossible evidentiary bars for legitimate claimants.

If you conducted real R&D and incurred real expenditure, you can substantiate that claim even if your records aren’t perfect.

The ATO’s documentary requirements are stricter than the law demands. Courts consistently recognise this. When businesses challenge disallowances and present credible alternative evidence, they often succeed.

But “can be substantiated” doesn’t mean “will be substantiated easily.” Without good contemporaneous records, you’re in for a harder, more expensive fight. You’re relying on reconstructed evidence, witness testimony, expert opinions. You’re building a case, not answering a checklist.

The smarter path: get your record-keeping right from the start. If you’re planning to claim the R&D offset, implement basic documentation practices now. Capture the information contemporaneously. Make it specific and technical.

If you’re already facing challenge and your records are incomplete, don’t assume you’ve lost. Understand the gap between the ATO’s position and what courts apply. Assess whether you can build a credible alternative case. Get specialist advice before you concede.

The record-keeping requirements set out by the ATO create circumstances where businesses conducting genuine R&D may fail to substantiate claims according to the ATO’s standards. But that shouldn’t be an indication the R&D tax offset won’t ultimately apply.

The expertise of a specialist litigator can make the difference when specific documents don’t exist. If the focus remains only on ATO guidelines and not the practical application of case law, companies miss opportunities to access an incentive they’ve legitimately earned.

This article provides general information only and does not constitute legal advice. Aptum Legal are specialists in commercial and tax litigation. For clarity in the pathway to resolving your R&D dispute, contact us today.