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.