Early stage tax disputes: a practical guide

A growing number of taxpayers can expect to be involved in ‘early stage’ (i.e. pre-tribunal) tax disputes over the coming years. Whilst every dispute turns on its own facts, there are some practical points of general application. Central to each of these is the importance of the taxpayer taking a careful, considered approach throughout the early stages – both in fulfilling its own obligations and ensuring that HMRC does not step beyond the limits of its authority. Failing to take care early in the process can risk unnecessarily prolonging disputes or storing up problems for later down the line.