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HMRC’s litigation and settlement strategy: an overview

Annis Lampard and Karmjit Mader (Deloitte) provide a back to basics guide to HMRC’s framework for resolving civil tax disputes.

HMRC’s litigation and settlement strategy (LSS) is the framework within which civil tax disputes are resolved in accordance with the law. It applies to both disputes resolved by agreement with the taxpayer or through litigation. The LSS covers the lifecycle of a dispute from the beginning of any compliance activity all the way to the conclusion of the matter.

The LSS was first introduced back in 2007 to ensure a consistent approach to resolving tax disputes across all taxpayers. Since 2007 the LSS has been revised and updated with the latest version dated October 2017 (see bit.ly/LSScommentary). In February 2023 HMRC’s Litigation and Settlement Strategy Manual (at LSS10000 onwards) further introduced a new guidance manual for staff on the LSS. This reinforces the principle that HMRC...

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