Revenue & Customs Brief 44/07

Litigation and Settlements Strategy (LSS)

The Litigation and Settlements Strategy (LSS) (PDF 61K) is relevant to all aspects of how HMRC enters into, handles and settles disputes about any of our taxes, duties or credits. It sets out principles for bringing tax disputes to a conclusion, whether by agreement with the taxpayer, or by litigation, i.e statutory appeal to an independent body, including the General or Special Commissioners, the VAT Tribunal, or the courts.

The aim of the LSS is to ensure that we conduct disputes in a way that is professional, effective and that supports HMRC’s objectives to close the tax gap and provide customers with a clear understanding of the law.
The central themes of the LSS are:

• Seek non-confrontational solutions where possible.
• Focus on issues that will best serve HMRC’s goal of tax gap reduction.
• Choose cases for their wider impact, as well as for their own value.
• Where we have a strong case we should seek full value from settlement, or take the matter to litigation.
• Do not pursue weak arguments.
• Team-work cases with colleagues, including those in other parts of HMRC.

Contact information

Andrew Page (HMRC Central Compliance)

Issued 11 June 2007