Dispute resolution
Tax Dispute Resolution
Disputes with HMRC can be protracted, sometimes needlessly so.
Failures to understand a business, or to communicate a complex fact pattern, might prevent solutions being found. Likewise prejudices on either side might be reinforced by the wrong approach being taken early on. Views can become entrenched, with both sides adhering to fixed positions.
In these situations the tax adviser needs to support the client and work with legal teams to ensure that matters are concluded as efficiently as possible- as the costs of ongoing disputes can mount up.
These days, HMRC takes a policy driven approach to settling disputes , and reviews of decisions by individual officers may be sought. at any stage. The introduction by HMRC of ADR (‘Alternative Dispute Resolution’) also means that there are alternatives to heading for the courts. However, if an HMRC officer is not willing to budge from a misconception then, unfortunately, litigation might be the only answer and formal assessments, appeals and closure notices will have to be taken to the tax tribunal.
Whatever the situation, there is always more than one approach to be considered.
