We are not looking to litigate as many cases as possible. Litigation involves expense and delay for both HMRC and our customers. Accordingly, agreed terms for settlement should always be sought before going to litigation. However, settlement terms must be consistent with the reasons for undertaking an enquiry in the first place, which are to influence taxpayer behaviour positively and to challenge behaviours that contribute to the tax gap.
| Additional Guidance: SVM150000 |
