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Deal or No Deal?

Chris Oates of Ernst & Young looks at how the HMRC's Litigation Settlement Strategy has worked in practice
Nearly two years ago I speculated on the potential impact and challenges that HMRC's Litigation Settlement Strategy (LSS) would bring. The strategy had only just been announced and it provided taxpayers and the profession with the guidelines that HMRC would adopt in determining whether disputes would be resolved through litigation or by negotiated settlement.
Before looking at how the LSS has been operating in practice it may be useful if we briefly remind ourselves of the general principles:
●     HMRC is no longer able to agree a single settlement sum to cover a range of open issues — there is a requirement to evaluate and decide each of the...

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