Richard Clarke and Jessica McLellan provide this month’s update on recent HMRC activity
Litigation or settlement?
Since 2007 the Litigation and Settlement Strategy (LSS) has governed how HMRC have approached dispute resolution. In recent months senior HMRC officers have questioned whether the LSS has been fully understood both by those inside HMRC as well as those outside (see ‘View from HMRC: dispute resolution’ Anthony Inglese and Geoff Lloyd Tax Journal 10 January 2011).
Some of these misunderstandings have unfortunately led all too often to a confrontational approach. With minimal engagement some officers have seemed determined from the beginning that a case should progress to litigation and may have decided that a relentless pursuit of every piece of supporting documentation was needed to understand a case fully.
Enquiries have then been delayed for long periods at the information-gathering...
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Richard Clarke and Jessica McLellan provide this month’s update on recent HMRC activity
Litigation or settlement?
Since 2007 the Litigation and Settlement Strategy (LSS) has governed how HMRC have approached dispute resolution. In recent months senior HMRC officers have questioned whether the LSS has been fully understood both by those inside HMRC as well as those outside (see ‘View from HMRC: dispute resolution’ Anthony Inglese and Geoff Lloyd Tax Journal 10 January 2011).
Some of these misunderstandings have unfortunately led all too often to a confrontational approach. With minimal engagement some officers have seemed determined from the beginning that a case should progress to litigation and may have decided that a relentless pursuit of every piece of supporting documentation was needed to understand a case fully.
Enquiries have then been delayed for long periods at the information-gathering...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")