What changes has HMRC made to its guidance on handling tax disputes? How will this affect disputes (now and going forward)?
HMRC’s litigation and settlement strategy (LSS) the code of governance for resolving tax disputes (‘the code’) and the commentary on the LSS (‘the commentary’) form the framework within which HMRC seeks to resolve tax disputes through civil procedures. This framework was first put in place in 2007 but has been updated a number of times most recently with effect from October 2017. This refresh is welcome given the changing nature and growing number and value of tax disputes; according to HMRC’s annual accounts over £9bn of tax disputes were referred to the Tax Disputes Review Board (TDRB) in 2016/17 compared to approximately £3bn in 2015/16 and the number of referrals increased by over 50% year on year.
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