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HMRC internal manual

Appeals reviews and tribunals guidance

Introduction: Litigation and Settlement Strategy

The aim of HMRC’s Litigation and Settlement Strategy is to make sure that we conduct disputes in a way that is professional, effective and that supports our objectives to close the tax gap and provide customers with a clear understanding of the law.

Operation of the new appeals and tribunal’s process must be consistent with this aim, and officers having any involvement with the resolution of disputes, in particular those conducting reviews, see ARTG4000 onwards, must be aware of the content of the Strategy and act in line with it.

HMRC expects all its staff, including review officers, tribunals caseworkers, and their managers, to act in line with the rule of law and the principles of justice, to act ethically and with integrity at all times. Review officers and Tribunals caseworkers should not act in any way that would conflict with those principles. If they have any concerns they should discuss the matter with their manager or consult the Whistleblowing and Raising a Concern guidance.

In this guidance the term ‘Case Board’ includes the following:

  • The Commissioners
  • Tax Disputes Resolution Board
  • Enforcement & Compliance Disputes Resolution Board
  • Specialist Personal Tax Disputes Resolution Board
  • Large Business Disputes Resolution Board
  • Transfer Pricing Board
  • Transfer Pricing Panel

In this guidance the term ‘Issues Panel’ includes the following:

  • Personal Tax Contentious Issues Panel
  • Business Tax Contentious Issues Panel
  • Anti-Avoidance Board