The Appeals Team stand ready to offer informal advice in any
case in which it appears that a dispute with the taxpayer(s) /
agent cannot be avoided.
If litigation is a possibility the sooner that appropriate
preparations are commenced the better (even if there remains a
chance that litigation can eventually be avoided)
In cases referred formally, the Appeals Team will conduct a
thorough review of the case to enable a fully informed decision on
litigation to be made. Such a decision will be taken in accordance
with the key principles set out at Chapter 116 of this manual
SVM116090. The decision may be taken
following the benefit of advice from an outside independent expert.
Where the Appeals Team decides that a case is not suitable
for immediate litigation, having taken any appropriate legal or
specialist advice, it will determine how the case should be taken
forward with the aim of ensuring an early settlement of the case.
Where the Appeals Team decides that litigation may be
appropriate, it will consult with the appropriate HMRC partners
with a view to seeking agreement on the proposed way forward.
| Additional Guidance: SVM150000 |
