Alternative dispute resolution (ADR) processes to manage tax disputes have been used by HMRC as ‘business as usual’ for over a year. The traditional one day mediation is used for both SMEs and individuals; and in large and complex cases – an independent HMRC officer facilitates the first group, and a third party professional mediates the second. Increasingly, because of the nature of the issues involved, the use of facilitated structured discussions are used in large and complex cases using two mediation trained facilitators, one for each party, over a number of days. Mediation and facilitation techniques also have an application in managing international double tax treaty disputes between states, to improve the resolution of international tax disputes which are set to increase further as a result of the OECD/BEPS initiatives.
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