HMRC's refreshed Litigation Settlement Strategy (LSS) has now been supplemented by two draft practical guidance notes both published on 14 August 2011.
The first is draft guidance on the LSS itself (LSS guidance).
The second is draft guidance on the use of Alternative Dispute Resolution (ADR guidance).
Although the ADR guidance is for the use of ADR in large or complex cases I have no doubt that it will apply equally to resolving SME cases. The LSS (and in particular paras 9 and 17) apply to all tax disputes.
There have conventionally been two strategies for resolving tax disputes: litigation and...
