Recently, HMRC have indicated a growing willingness to reach settlements across a broad spread of issues. While adapting their guidance and training on the Litigation and Settlement Strategy, HMRC are also trying mediation methods through the Alternative Dispute Resolution pilot which they are looking to extend. Some large corporates are now entering their second financial period subject to the Senior Accounting Officer regime, raising questions about whether HMRC’s ‘light touch’ approach will develop into a more in-depth dialogue. On the international front, the final ruling in Laerstate BV v HMRC will be likely to drive more HMRC challenges to claims of corporate non-UK residence while the UK government draws nearer to announcing a deal with the Swiss authorities regarding exchange of information and withholding tax.
