During a week in which the House of Lords has listened to the infamous dispute between HMRC and Mr and Mrs Jones (Arctic Systems), HMRC have published their litigation and settlements strategy (LSS) document, setting out principles for bringing tax disputes to a conclusion, whether by agreement with the taxpayer, or by litigation.
The aim of the LSS is to ensure that HMRC conduct disputes in a way that is professional, effective and that supports their objectives to close the tax gap and provide customers with a clear understanding of the law.
The main themes of the LSS include:
- seeking non-confrontational solutions where possible;
- focusing on issues that will best serve HMRC’s goal of tax gap reduction;
- choosing cases for their wider impact, as well as for their own value;
- seeking full value from settlement, where there is a strong case, or taking the matter to litigation;
- not pursuing weak arguments; and
- emphasising the importance of team-work cases with colleagues, including those in other parts of HMRC.
Anyone dealing with HMRC should find the document a useful reference tool.
Link
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