Examining the tax assurance commissioner’s latest report

The tax assurance commissioner’s latest report contains statistics that confirm what practitioners are seeing when advising clients: it is becoming harder to settle disputes with HMRC. There have been marked reductions both in the number of referrals to governance boards and in the proportion of referrals that are authorised for settlement; the rejection rate has gone up from 23% three years ago to 52% this year. While HMRC’s success in litigation justifies a tightening of what it is willing to settle for, taxpayers have also moderated their offers. These trends are therefore unexplained, but they mean that taxpayers with disputes need to pitch settlement offers very carefully.