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HMRC internal manual

Compliance Handbook

Litigation and settlement strategy: deciding whether to pursue a dispute

In general, where there is a point of dispute on the treatment of a matter, the Litigation and Settlement Strategy (LSS) says that we will not take that dispute further unless the overall revenue flows potentially involved justify doing so.

You must consider

  • not only what is at stake in the dispute itself
  • but also - in cases where a precedent may be set, or where we are seeking to influence the person’s behaviour - potential tax liabilities of the same or another person.

See the operational guidance at CH280000+, which explains in detail what you are likely to consider.

In any tax dispute you must decide

  • how to move the dispute towards resolution, and
  • the terms on which HMRC may be ready to resolve the dispute (in the absence of a finally binding outcome from litigation).

See CH280200, for operational guidance about deciding whether to take a dispute forward.