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HMRC internal manual

Tax Compliance Risk Management

Risk Working: Action Plans: Action Plans and litigation

During the litigation stages we may have less control over timescales. However planning is still important to manage the lead up to hearings and track the risks as they move through the appeals process. These cases, including European Court of Justice (ECJ) cases, must continue to be reflected in the APs and monitored by the CRM and the Deputy Director.

When a risk moves into the litigation phase (as opposed to ‘towards litigation’) in ‘Lead’ cases the date of the next tribunal/court date and what the stage is should be entered in the Action Plan. In ‘Following’ cases the lead case should be named in an Action Plan.