Mediation as a means of resolving commercial disputes involving tax has been around for ages but has only come to the fore in disputes with HMRC in the last six years or so. In tax disputes mediation is used in two separate contexts. First there are tax disputes that do not involve HMRC at least not directly in the sense that HMRC is not a party to the dispute. Examples of such disputes include disputed tax liabilities arising out of the tax warranties and indemnities given by the parties to each other on the sale of a business or a company; and also disputes as to liability for negligent tax advice where a client is claiming against his tax adviser for bad tax advice. The second context is where a taxpayer and HMRC are seeking to avoid litigating their dispute before the tax tribunals and the courts...
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Mediation as a means of resolving commercial disputes involving tax has been around for ages but has only come to the fore in disputes with HMRC in the last six years or so. In tax disputes mediation is used in two separate contexts. First there are tax disputes that do not involve HMRC at least not directly in the sense that HMRC is not a party to the dispute. Examples of such disputes include disputed tax liabilities arising out of the tax warranties and indemnities given by the parties to each other on the sale of a business or a company; and also disputes as to liability for negligent tax advice where a client is claiming against his tax adviser for bad tax advice. The second context is where a taxpayer and HMRC are seeking to avoid litigating their dispute before the tax tribunals and the courts...
If you are not a subscriber, subscribe now to read this content.
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