Dear Sir
The recent article authored by Geoff Lloyd and Anthony Inglese (HMRC) (‘View from HMRC: dispute resolution’ Tax Journal 10 January 2011) was a welcome contribution to the continuing debate around tax dispute resolution. In particular it was helpful for HMRC to publish a single well considered message addressing some of the key questions and concerns which have arisen over recent times (the article referred to some of these as ‘three common misunderstandings’). HMRC’s effort to build an inclusive approach to dispute resolution (eg in the SME sector) is also to be welcomed.
It seems to be widely accepted that a collaborative approach is likely to be the best context to achieve the objective and I would certainly endorse this based on experience. The article also indicates recognition that at the appropriate stage of a dispute more valuable effort could be spent in exploring...