Comment by CamouflagedKiwi

I've dealt with this at a previous employer (where we did try to be reasonably honest and submitted things that had some R&D element, I can imagine a less principled approach). The concept of it seems sensible, in practice you end up justifying why something is R&D to essentially non-technical people, probably at some consultancy who can then repeat a moderately garbled version of your description to HMRC who presumably just approve in most cases because they also don't have the expertise to truly assess the subject matter (and let's face it, we'd all struggle, even if we believe we're expert software engineers, how do you assess whether work on a mortgage issuing product for a bank is truly R&D if you have no familiarity with the domain).