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HMRC internal manual

Shares and Assets Valuation Manual

The Litigation and Technical Advice Team (LTAT): Contentious Cases

The LTAT are happy to offer informal advice in any case in which it appears that a dispute with the customer and / or their agent cannot be avoided.

If litigation is a possibility the sooner that appropriate preparations are commenced the better (even if there remains a chance that litigation can eventually be avoided)

In cases referred formally, the LTAT will conduct a thorough review of the case to enable a fully informed decision on litigation to be made. Such a decision will be taken in accordance with the key principles set out at Chapter 116 of this manual SVM120080. The decision may be taken following the benefit of advice from an outside independent expert.

Where the LTAT decides that a case is not suitable for immediate litigation, having taken any appropriate legal or specialist advice, it will determine how the case should be taken forward with the aim of ensuring an early settlement of the case.

Where the LTAT decides that litigation may be appropriate, it will consult with the appropriate HMRC partners with a view to seeking agreement on the proposed way forward.

  Additional Guidance: SVM150000