Alternative Dispute Resolution (ADR) has been a significant feature on the landscape of commercial litigation for the past 11 years. In relation to tax, the concept of ADR first emerged last year in the rules for the new Tribunal. Since then there has been a steadily increasing amount of debate around the subject and HRMC has now indicated that it is looking to pilot ADR in specific cases, albeit not yet rolling it out as being a standard part of tax dispute resolution procedure. There now exists a real opportunity to establish a new means of dispute resolution which has the potential to reduce significantly the number of appeals ending up in the Tribunal.
