SPEED READ HMRC’s approach is to seek to resolve disputes as efficiently as possible, securing the tax due under the law at the least cost to HMRC and at the least cost (in the widest sense) to our customers. It is sometimes said that HMRC’s Litigation and Settlement Strategy (LSS) stands in the way of a collaborative and commercial approach to resolving disputes. This isn’t the case, and a number of misunderstandings persist about how the LSS operates in practice. A first misunderstanding is that where HMRC is advised that we have a 51% chance of success we will always litigate. A second misunderstanding is that the LSS lacks flexibility, especially in that it is said to direct HMRC unnecessarily to see all issues in dispute as black/white. The third misunderstanding is that LSS decisions do not take account of litigation risk. None of these are true.
