SVM117010 - 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:

Cases

• Over 18 months old where retention in the team has not been approved by your manager;
• 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 case owner requests a valuation for a Closure Notice or the customer requests a formal review under the Tribunal rules;
• another HMRC Appeals Unit is involved or mentioned;
• valuations that have been referred to SAV for consideration following the issue of a discovery assessment because time limits may apply;
• 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 in conjunction with your manager.

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