Fire away!

Key points * The new strategy and the purpose behind it. * A reduction in the 'middle ground'? * Guidelines when seeking a settlement. * What happens when 'avoidance' is contended? * The consequences of the new approach. * Is increased litigation the best route?

THE LATEST SALVO in HMRC's campaign to raise the profile of tax compliance — especially in the large corporate model — has been the publication of its litigation and settlement strategy (LSS): a document which provides guidelines in determining the criteria by which HMRC will decide whether or not disputes should be resolved through litigation or negotiated settlement. (See HMRC website at www.hmrc.gov.uk/practitioners/lss-intro.htm.)
One of the major drivers for the LSS has following the merger of Customs & Excise and Inland Revenue been a growing unease within the department that many Inspectors of Taxes were prepared to reach negotiated settlements with taxpayers...