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Code of governance for resolving tax disputes

The code of governance for resolving tax disputes sets out HMRC's internal governance for decisions on how tax disputes should be resolved.

Most disputes are resolved collaboratively and by agreement, and only a very small minority of disputes need to be resolved by legal action, either in a tribunal or a higher court.

The litigation and settlement strategy (LSS) (see A5.901 and De Voil Indirect Tax Service V5.400C), sets out the basis on which HMRC will reach agreement in a tax dispute. The arrangements described in the code are intended to provide assurance that the principles of the LSS are applied consistently in practice to the resolution of tax disputes.

Decision on the resolution of certain high value or sensitive disputes must be taken by three tax-expert HMRC Commissioners, including the Tax Assurance Commissioner. The referral to the Commissioners includes the recommendations on the case from a panel of senior tax professionals known as the Tax Disputes Resolution Board (also known as the TDRB, see 'Tax Disputes