We now have a final LSS and ADR guidance although the tax disputes world seems to have been operating on the draft ‘refreshed’ version since last July.
The LSS commentary hasn’t changed materially although the governance section will need to change to reflect the new Governance Code of Practice when it's published including the role of the new Assurance Commissioner. Fundamentally the strategy still has the same issues hanging over it discussed many times in this journal – when is a case ‘all or nothing’ why does it matter that a taxpayer has several ‘all or nothing’ issues how should HMRC reconcile its wider tax management duties and so on. These haven't been resolved and will continue to...
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