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HMRC internal manual

Compliance Handbook

Litigation settlement strategy: handling a dispute: agreeing timescales

When you have set out the point or points in dispute clearly, see CH40730, it may be helpful to agree a timetable for the next steps. You should discuss and agree steps and target dates or milestones with the person we are in dispute with or their agent.

The detail of the timetable will depend on

  • the nature and complexity of the point in dispute and
  • what both parties consider would be helpful to document.

It may not be appropriate, or even possible, to fix a firm timetable for all stages in resolving the dispute as later stages may depend on the outcome of earlier stages or on the outcome of work being undertaken in relation to other cases. However, it can still be helpful for both parties to outline expected timescales.

You should not agree a firm timetable until you have established that any other HMRC stakeholder who may be involved in the case or decision-making process can meet the proposed deadlines.

You must also take account of any statutory provisions that limit the time available for HMRC to take action.