HMRC seems more amenable to alternative dispute resolution, whilst also pushing for greater formality in tax appeals, report Adam Craggs and Constantine Christofi (RPC).
Rise in alternative dispute resolution
Until relatively recently HMRC imposed strict conditions on the timing of when an application for alternative dispute resolution (ADR) could be made refusing to consider any application which was made after it had formally set out its position in its ‘statement of case’. This gave taxpayers a limited window during which to apply for ADR after HMRC’s enquiries had concluded. This unilaterally imposed restriction on the timing of ADR applications was disappointing principally because there was no statutory basis for it. It also seemed counter-intuitive to treat the provision of HMRC’s statement of case as a barrier to ADR when delivery of that document provides both parties with an opportunity to reappraise their respective positions and consider...
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HMRC seems more amenable to alternative dispute resolution, whilst also pushing for greater formality in tax appeals, report Adam Craggs and Constantine Christofi (RPC).
Rise in alternative dispute resolution
Until relatively recently HMRC imposed strict conditions on the timing of when an application for alternative dispute resolution (ADR) could be made refusing to consider any application which was made after it had formally set out its position in its ‘statement of case’. This gave taxpayers a limited window during which to apply for ADR after HMRC’s enquiries had concluded. This unilaterally imposed restriction on the timing of ADR applications was disappointing principally because there was no statutory basis for it. It also seemed counter-intuitive to treat the provision of HMRC’s statement of case as a barrier to ADR when delivery of that document provides both parties with an opportunity to reappraise their respective positions and consider...
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