R&D qualification requires more than just writing software
The <a href="https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird100000">merged R&D scheme requires genuine technical uncertainty and a project that seeks an advance in science or technology</a>. Software firms that build bespoke systems for clients may qualify where the project involves a genuinely novel technical problem. Work that applies well-established techniques to new business requirements does not qualify, even if it is technically demanding from the client's perspective. The honest boundary is the trust moat versus R&D mills.