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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Litigation and settlement strategy: Handling a dispute: where collaborative approach is not possible or appropriate

Neither HMRC nor the person we are in dispute with can be unilaterally collaborative. A collaborative approach requires both parties to work together on a co-operative, non-adversarial basis in order to resolve a dispute.

You may not be able to adopt or continue with a collaborative approach if, for example

  • the person or their agent is unwilling to co-operate or discuss matters openly
  • there are persistent unexplained delays or missed deadlines that mean the dispute cannot be resolved in an efficient or cost effective manner
  • it appears the person or their agent is seeking to deliberately mislead or otherwise act dishonestly towards HMRC. However, a compliance check into past evasion should not automatically rule out collaborative dispute resolution where the person or agent is willing to co-operate.

Even in such cases, you should be open to collaboration if a person changes their approach.

If a collaborative approach is not possible or appropriate, you should progress the dispute by the most efficient and effective means in the circumstances. For example, you may need to use the statutory information powers, see CH20000 onwards.