HMRC's Litigation and Settlements Strategy

Just over a year ago HMRC published its Litigation and Settlements Strategy (LSS) setting out its approach to the resolution of disputes with taxpayers. In particular the document focuses on the relevant factors for HMRC when deciding whether to agree a settlement on the issues in question or instead to proceed to litigation. What comes across clearly from the paper is that HMRC is not afraid to litigate where it considers it appropriate. Does this mean that settlements are less achievable going forward and we will see an upturn in litigation? Statistics from the VAT Tribunal and Special Commissioners would suggest that the...