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Needs must: HMRC's creative use of the LSS

In his article on PBR 2009 (Tax Journal 11 January 2010 p 9) my colleague James Bullock wrote that some of the statements made in HMRC's Protecting Tax Revenues 2009 publication suggested that a realignment of HMRC's 'Litigation and Settlement Strategy' (LSS) may be afoot.

He highlighted that the LSS had had the (perhaps intended) effect of blocking the dispute resolution 'pipeline' but that this was having serious consequences for HMRC and depriving it of badly needed cash in the meantime.

Since then we have told whoever would listen that we expected there to be some form of 'amnesty' for disputes where favourable terms for settlement would be offered for a limited period in order to collect some cash and free up resources to fight what was left.

The Lease Premium Settlement Initiative

On 7 June HMRC announced a form of 'amnesty'...

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