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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Litigation and settlement strategy: resolving a dispute: all or nothing disputes

An ‘all or nothing’ issue is one which has only two possible outcomes: either a given amount is due or it is not.

Where a dispute relates to an all or nothing issue you must not accept any out of court resolution that splits the difference.

Sometimes a dispute that initially appears to be an all or nothing issue may turn out to be one where there is a range of possible figures. Wherever an issue initially appears to be all or nothing, you should explore (preferably with the person) whether or not

  • there is a range of right answers for how the law should be applied to the facts, or
  • the issue can be broken down into two or more sub-issues, each of which can be resolved separately.

See the example at CH40860.