Where HMRC believes that it is likely to succeed in litigation and that litigation would be both effective and efficient, it will not reach an out of court settlement for less than 100% of the tax, interest and penalties at stake.
HMRC’s Litigation and Settlement Strategy (LSS) is the framework within which HMRC resolves tax disputes through civil law processes and procedures. It applies irrespective of whether the dispute is resolved by agreement with the customer or through litigation.
The LSS is designed to facilitate resolution of disputes in relation to all taxes, duties and associated payments.
A key part of HMRC’s overall strategy is to help reduce the likelihood of situations arising which may give rise to a dispute. Tax disputes may be resolved either by agreement or through litigation. Where there is a range of possible figures for tax due, the terms on which HMRC will settle by agreement will also take into account which outcome secures the right tax most efficiently.
In considering settlement terms for one dispute, HMRC will take account of the potential read across to other open or prospective disputes as well as the impact which settling the dispute could have in releasing HMRC resources to work on other disputes.
Where HMRC believes that it is likely to succeed in litigation and that litigation would be both effective and efficient, it will not reach an out of court settlement for less than 100% of the tax, interest and penalties at stake.
Our team of experts at Templeton Brook Witt have assisted a number of clients with their HMRC settlement. If you need assistance with negotiations and settlement with HMRC, call us for a free no obligation consultation today.
Your Trusted Advisors
Based in the landmark St. Mary Axe, Templeton Brook Witt provide specialist tax investigations, compliance advisory and employment dispute advice to private clients and corporates.
0207 889 1000
info@templetonbrookwitt.com
30 St. Mary Axe, The Gherkin
Level 28
London
EC3A 8BF
© 2023 Templeton Brook Witt Ltd. All rights reserved.