A5.712 Litigation and settlement strategy

Administration and compliance

A5.712 Litigation and settlement strategy

HMRC policy on disputes

A5.712 Litigation and settlement strategy

HMRC set out its policy for dealing with taxpayer disputes in the litigation and settlement strategy (LSS). The strategy is relevant to all aspects of how HMRC enters into, handles and settle disputes about any of their taxes, duties or credits1. It was first published in 2007 and has been revised a number of times since then. The LSS and its accompanying guidance is a stand alone reference source, to be read in conjunction with the HMRC manuals. HMRC expects all officers who are involved in dispute resolution to be familiar with it2. The LSS falls within HMRC's overall code of governance for resolving tax disputes, see A5.712A.


While the LSS is summarised below, the HMRC guidance accompanying it is clear that is an overall approach. Parts of the strategy and the guidance alongside it should not be read or interpreted on their own, or taken out of context.

The strategy sets out principles for bringing tax disputes to a conclusion, and the relevant factors for HMRC to consider in deciding whether to agree a settlement with the taxpayer or to proceed to litigation, ie statutory appeal to an independent body, including the tribunals or the courts. Broadly, the aim of the LSS is to ensure that HMRC handles disputes effectively and efficiently, with the aim of reaching swift

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