EY reports that ‘HMRC has recently informed us that it intends to ratchet up the availability of ADR (mediation) as a means of bringing significant disputes and long-running or stalled enquiries to resolution’. According to its weekly tax briefing, this ‘includes opening up the HMRC ADR process to disputes about HMRC information notices and – to a greater extent than before – to larger and more complex disputes, including those involving companies dealt with by HMRC Large Business. HMRC has identified R&D enquiries as a particular area where it recognises that ADR may be of benefit, but we understand that it is open to considering a greater use of ADR across all larger disputes or enquiries involving the full range of taxes or duties.’
ADR is a flexible process typically involves a single day mediation using an outside HMRC mediator not involved directly in the case, with the option for the taxpayer to appoint their own accredited mediator, with discussions taking place on a ‘without prejudice’ basis.
EY reports that ‘HMRC has recently informed us that it intends to ratchet up the availability of ADR (mediation) as a means of bringing significant disputes and long-running or stalled enquiries to resolution’. According to its weekly tax briefing, this ‘includes opening up the HMRC ADR process to disputes about HMRC information notices and – to a greater extent than before – to larger and more complex disputes, including those involving companies dealt with by HMRC Large Business. HMRC has identified R&D enquiries as a particular area where it recognises that ADR may be of benefit, but we understand that it is open to considering a greater use of ADR across all larger disputes or enquiries involving the full range of taxes or duties.’
ADR is a flexible process typically involves a single day mediation using an outside HMRC mediator not involved directly in the case, with the option for the taxpayer to appoint their own accredited mediator, with discussions taking place on a ‘without prejudice’ basis.
