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HMRC internal manual

Compliance Handbook

Litigation and settlement strategy: how to use this guidance

This guidance explains some detail about HMRC’s Litigation and Settlement strategy (LSS). The full text of the LSS is at CH40350.

This guidance applies to all compliance work across HMRC but does not aim to be comprehensive, nor will every element of it be applicable in every case.

For example, special considerations might apply to the resolution of disputes involving

  • NICs, where a dispute may affect an individual’s contributory record as well as the amount of contributions payable
  • PAYE, where the outcome of a dispute may affect an employee’s tax liability
  • VAT, where the outcome of a dispute may affect others in the supply chain.

You should therefore read this guidance alongside any more detailed operational and policy guidance that applies to your case.