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HMRC internal manual

Compliance Handbook

Litigation and settlement strategy: resolving a dispute: cases in litigation

Resolving disputes by agreement is likely to be the most cost effective outcome in the majority of cases.

But where it is cost effective to litigate, that route should be actively pursued with the aim of resolving the dispute as quickly and cost effectively as possible.

Litigation refers to the taking of tax appeals or other areas of dispute through a formal judicial process involving the tribunals and the courts.

Further guidance on litigation and rights of appeal, judicial review and statutory internal reviews is in the Appeals, Reviews and Tribunals Guidance (ARTG).

Even where one party has, or both parties have, decided to litigate a particular matter, you should continue to be open to considering the impact of any new information and analysis. In certain circumstances, this may provide a basis for resolving a dispute by agreement without the need for litigation.