The following Personal Tax guidance note by Tolley in partnership with Simon Oakes provides comprehensive and up to date tax information covering:
HMRC’s litigation and settlement strategy (LSS) governs how HMRC conducts civil law disputes. ‘Disputes’ in this context is given a wide meaning as explained below. The LSS covers most of HMRC’s compliance activity but does not apply to criminal investigations.
Advisers need to be aware of the LSS because it set out a series of generic principles that govern how HMRC intends to conduct civil disputes to ensure this is done proportionately and within the law, in a way that minimises the number of ongoing disputes.
The LSS, and its attendant commentary, is drafted in sufficient detail to provide a ready means of holding HMRC to account (eg through its complaints process) if during any dispute HMRC fails to follow these principles.
Special considerations might apply for disputes involving NICs, PAYE or VAT. This is due to the possible implications for an individual’s contribution record in the case of NICs, and the tax treatment of other taxpayers in the case of PAYE and VAT disputes. The LSS should always be read in conjunction with the HMRC published operational and policy guidance that applies to the particular dispute in question.
This guidance note:
The current wording of both the LSS and the accompanying commentary / guidance for HMRC staff can be found on the GOV.UK website .
The LSS, and its accompanying guidance, sets out a holistic approach to HMRC’s compliance work. No one paragraph or sentence should be
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