Dawn Register and Talia Greenbaum look at the options for resolving disputes with HMRC and recent results
Very few people actually want to have their ‘day in court’. For most taxpayers, taking a case to the Tax Tribunal to obtain a judicial ruling is expensive, time consuming and often rather daunting, to say the least.
The Tribunal is also a measure of last resort for HMRC. For the tax authority too it is expensive, a drain on limited resources and can lead to long delays in collecting tax revenue. Even following the introduction of Accelerated Payment Notices (APNs) and Follower Notices (FN) in tax avoidance cases there are still thousands of disputes where tax remains uncollected whilst the tax position is unresolved.
It is therefore in everyone’s interest if disputes can be resolved satisfactorily without the need to resort to the Ministry of Justice.