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HMRC internal manual

Shares and Assets Valuation Manual

The Litigation and Technical Advice Team (LTAT): Cases to be referred to the Litigation and Technical Advice Team (LTAT)

You should refer cases within the following categories:


  • Over 18 months old and retention in the team has not been approved at Grade 6 level;
  • negotiations have reached deadlock and it is time to consider whether litigation is appropriate;
  • negotiations are not progressing satisfactorily and it is appropriate to seek advice on what preparations for litigation might be undertaken whilst efforts at negotiation continue;
  • third party enquiries are considered necessary or it is proposed to use third party formal information powers;
  • the advice of an outside independent expert may be required;
  • the Inspector requests a valuation for a Closure Notice or the taxpayer requests a formal review under the Tribunal rules;
  • another HMRC Appeals Unit is involved or mentioned;
  • valuations have been referred to SAV for consideration of, or following the issue of, a discovery assessment;
  • valuations are requested for purposes of possible confiscation of assets by a criminal court;
  • a possibility of a judicial review (see SVM117040 below) is mentioned;
  • a penalty is being considered under Schedule 24 Finance Act 2007.
  • Business Relief or Agricultural Relief advice is required and your Grade 7 is unable to resolve the matter.

Any formal reference to the LTAT should be made via your manager.

  Additional Guidance: SVM150000