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Commentary

A5.901 HMRC's litigation and settlement strategy

Administration and compliance

For updates affecting this Division please see Part A0 Updates

HMRC policy on disputes

A5.901 HMRC's litigation and settlement strategy

HMRC set out its policy for dealing with taxpayer disputes in the litigation and settlement strategy (LSS). The strategy is relevant to all aspects of how HMRC enters into, handles and settle disputes about any of their taxes, duties or credits1.It was first published in 2007 and has been revised a number of times since then. The LSS and its accompanying guidance is a standalone reference source, to be read in conjunction with the HMRC manuals. As well as the LSS framework itself HMRC has published a discrete manual on the LSS2. HMRC expects all officers who are involved in dispute resolution to be familiar with it3. The LSS falls within HMRC's overall code of governance for resolving tax disputes, see A5.902 and De Voil Indirect Tax Service V5.400D.

Summary of the litigation and settlement strategy

While the LSS is summarised below, the HMRC guidance accompanying it is clear

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