ADRG02800 - Alternative Dispute Resolution (ADR) is not suitable for every dispute

Mediation will only be used in cases where there is a potential benefit right at the start. It should not be used if there is no realistic prospect of any progress and further discussion will just delay matters.

If the customer doesn’t want mediation, then it will not happen.

In some cases, HMRC may want to get a “test case” before the Tribunal to get a ruling on a disputed issue that is occurring in several other similar cases, so mediation may not be available, depending on the particular circumstances.

Mediation may not be useful where there is significant doubt about the veracity or strength of the evidence provided and HMRC wish to test it by cross-examination at Tribunal.