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HMRC’s refreshed LSS: no ‘soft’ option

The new policy document could hinder tax officials in their work, warn Peter Nias and Barbara Belgrano

The litigation and settlement strategy (LSS) sets out the framework and approach to be adopted by HMRC when handling and resolving tax disputes subject to civil law procedures and is intended to ensure that HMRC applies the law fairly and even-handedly. It was introduced in 2007 and a refreshed version was issued in April this year. It applies to all stages of a dispute.

There was concern when it was first published as a draft last year that the refreshed version suggested that HMRC would be taking a ‘softer’ approach to dispute resolution.

As this article will show that is far from being the case and the real concern should be whether this policy document designed to allow HMRC officials to carry on their business in fact...

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