HMRC’s annual report and accounts 2020-21 state: ‘Alternative dispute resolution (ADR) is a flexible dispute resolution tool which can help HMRC and the taxpayer resolve disputes (or reach key decision points) in a cost-effective and efficient manner. Although available at any point of a compliance check or enquiry most ADR applications are made once we have made a decision and the customer has appealed to the tribunal. The availability of ADR at any stage of litigation proceedings was highlighted in June 2020 in a tribunal practice statement. Taxpayers may apply online for ADR. Where our mediators have concerns about whether ADR will be effective the case is referred to the appropriate governance panel for consideration. Where we agree to enter into ADR an impartial HMRC mediator will work with the HMRC caseworker and the taxpayer to try to resolve the dispute. ... The number of cases...
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