Corporate report

HMRC's annual report and accounts 2022 to 2023: tax assurance commissioner’s report

Published 17 July 2023

Foreword

The year 2022 to 2023 has been another demanding year for HMRC and I am happy that we have made good progress towards resolving tax disputes fairly and with consistency throughout. As the Tax Assurance Commissioner, and alongside HMRC’s other commissioners, I am proud of the work we have done to assure the resolution of HMRC’s most significant tax disputes. As commissioners, we also oversee our wider dispute resolution processes, including reviewing a sample of smaller cases which allows commissioners to assure a wider range of HMRC’s work.

There is sustained public interest in the way HMRC settles tax disputes, particularly for wealthy individuals and large Corporations. It is right that we are held to and deliver a high standard when settling disputes with taxpayers. I am committed to supporting every colleague to achieve these standards, through increased training, sustaining the focus on our Customer Charter and Compliance Professional Standards. This includes reinforcing our aim to resolve all disputes, regardless of their size, collaboratively and always in a fair and even-handed way.

Any proposal to resolve a dispute is considered in line with HMRC’s published Litigation and Settlement Strategy (LSS), which sets out that HMRC will not settle for an amount that is less than would be reasonably expected from litigation. I remain assured by both my oversight of the formal dispute governance boards, and the Tax Settlement Assurance Programme (TSAP) that this is the case.

We offer several ways for taxpayers and HMRC to reach a resolution outside of litigation. We have collated information on our governance processes into a single web page.

We have sought to improve customer understanding of HMRC’s dispute resolution mechanisms and have published a manual on Alternative Dispute Resolution (ADR). We have also enhanced the manual on the LSS, providing clearer explanation for HMRC staff and customers on how to apply the LSS and supported this with a programme of internal training which are continuing.

The results of our assurance programme evidence the improvements we are making in our compliance work. We have provided feedback to managers on areas where we could do better to ensure we consistently meet our standards. I am confident that HMRC colleagues will continue working to improve standards over the coming year, contributing to building further confidence and trust in HMRC’s administration of the tax system.

Justin Holliday Tax Assurance Commissioner and Chief Finance Officer

Our approach to tax disputes

The HMRC Charter defines the standard of service and behaviour that customers should expect when dealing with us. We are committed to meeting our Charter commitments and improving our customer experience. We closely monitor performance against our customer service standards and take steps to implement further improvements where necessary. We try to support our customers to fufil their obligations and pay the right tax without the need for a dispute.

We do this in several ways, including designing a framework of policy and guidance to help customers navigate through the tax system and resolve issues at first contact whether using digital or traditional channels.

However, we know there will be occasions where customers disagree with us on the amount of tax that is due. We seek to resolve any dispute as quickly and cost-effectively as possible, in accordance with the law, our Litigation and Settlement Strategy and our ‘Code of Governance for resolving tax disputes’. Where we cannot reach an agreement, there are several options that a customer or HMRC can take to agree a resolution, including mediation through Alternative Dispute Resolution (ADR). ADR is a flexible process which can be used by HMRC and customers to resolve disputes at any stage of a compliance check. Ultimately where this is not possible, a customer can request a statutory review and/or ask an independent tax tribunal to determine the dispute.

HMRC’s policy for dealing with tax disputes in cases involving fraud is to follow the cost-effective civil fraud investigation procedures wherever appropriate. We will respond robustly to those who try to cheat or attack the tax system. We reserve our criminal investigation powers for cases where HMRC needs to send a strong deterrent message, or where the conduct involved is such that only a criminal sanction is appropriate.

Read HMRC’s ‘Code of governance for resolving tax disputes’ at GOV.UK.

Read HMRC’s criminal investigation policy at GOV.UK.

Read HMRC’s Charter at GOV.UK.

How we resolve tax disputes

We resolve most tax disputes by agreement with customers. Customers can authorise someone else to deal with the matter on their behalf throughout the entire dispute process, such as an accountant, friend or a relative.

HMRC’s Litigation and Settlement Strategy (LSS) is the framework within which we resolve tax disputes through civil law processes and procedures in accordance with the law. It applies whether the dispute is resolved by agreement with the customer or through litigation. We aim to apply the law fairly and consistently, in order to secure the best practicable return for the Exchequer.

HMRC does not ‘do deals’ with anyone and resolves disputes in line with current law. We resolve each dispute according to the facts and circumstances of each case and do not enter into ‘package deals’ with anyone (where multiple disputes are considered together and traded off against each other), although we may settle different matters concurrently. HMRC only usually persists with a tax dispute where it believes that it will secure the best return for the Exchequer and that it would be successful in litigation. We ensure that both the substance of any decision leading to resolution of the dispute and the way that resolution is put into effect are fully in accordance with the law.

Governing the resolution of disputes

The role of the Tax Assurance Commissioner (TAC) was first introduced in 2012, as part of a package of measures to strengthen HMRC’s governance and assurance of tax disputes. The TAC has ultimate responsibility for civil dispute governance across HMRC, and for the Litigation and Settlement Strategy (LSS). They provide assurance and transparency to Parliament and the public that HMRC handles disputes in a fair and even handed manner, avoiding unnecessary disputes and conducting any disputes in a non-confrontational manner.

The TAC has no involvement in the management of the tax affairs of specific taxpayers and no line management responsibility for caseworkers, maintaining a clear separation of responsibilities. The majority of case resolution decisions are taken by caseworkers with the oversight of their managers and, where relevant, advice from specialists. A sample of cases is checked through HMRC’s Tax Settlement Assurance Programme to provide assurance of how cases are managed and disputes resolved. The TAC chairs a panel of 3 HMRC Commissioners who make decisions on the largest and most sensitive cases, as well as a sample of smaller cases.

Read HMRC’s Litigation and Settlement Strategy at GOV.UK.

If the tax at risk in a dispute is greater than £5 million (non-Large Business customers) or £15 million (Large Business customers), it falls within the remit of Customer Compliance Group Dispute Resolution Board (CCG DRB).

When the total tax at risk for all ongoing disputes with a customer exceeds £100 million, most individual disputes come within the remit of the Tax Disputes Resolution Board (TDRB), which makes recommendations to the commissioners on any proposal to resolve those disputes.

Figure 43: Summary of TAC oversight dispute resolution governance

The data and information presented in this chart is available in an alternative format within the HMRC’s annual report and accounts 2022 to 2023: chart data – tab 43.

In the financial year 2022 to 2023, the commissioners considered risks referred from the TDRB, as well as a sample of cases from the CCG DRB. The commissioners also considered risks referred to them by HMRC’s issues panels. HMRC’s dispute resolution governance boards are made up of senior leaders from across HMRC, including lawyers and representatives from policy, technical and operational areas, independent of the case team.

One case that had missed TDRB/ TAC governance was identified during 2022 to 2023. We understand how the failure arose and have taken steps internally to reduce the chances of a similar error occurring. The case was compliant with our Litigation and Settlement Strategy.

Table 10: HMRC Commissioners: outcome of referrals

	2022-23	2021-22
Total number of meetings held (including via correspondence)	22	18
Total referrals to the commissioners	56 (note 1)	49
Reason for referrals
£100m plus tax or £500m adjustment	36	34
Decisions on sensitive case or risk	5	2
Decisions on sample cases	11	10
Director referral	2	1
Direct re-referral following remittance for further work	2	2
Outcome of referral
Taxpayer’s position accepted	37	27
Taxpayer’s position rejected	12	19
Taxpayer’s position partially accepted	3	-
Taxpayer’s position partially rejected	-	1
Remitted for further work	4	2

Note 1: The above figures do not include referrals from Issues Boards as these are non-customer specific.

Table 11: HMRC Commissioners: tax under consideration in decisions referred to commissioners

	2022-23 (£m)	2021-22 (£m)
Taxpayer’s position accepted	9,368.2	3,238.2
Taxpayer’s position rejected	2,940.2	1,845.5
Taxpayer’s position partially accepted	174.2	-
Taxpayer’s position partially rejected	-	95.8
Remitted	29.1	84.9

Table 12: Tax Dispute Resolution Board: outcome of referrals

	2022-23	2021-22
Referrals to TDRB	46	38
Referred to commissioners
Taxpayer’s position accepted	31	21
Taxpayer’s position rejected	10	12
Taxpayer’s position partially accepted	3	-
Taxpayer’s position partially rejected	-	1
Total referred to commissioners	44	34
Not referred
Remitted for further work	1	1
Guidance provided	-	-
Decision taken by TDRB under its remit	1	3
Total not referred to commissioners	2	4

Table 13: The Customer Compliance Group Dispute Resolution Board: outcome of the total referrals to the CCG DRB

	2022-23	2021-22
Total referrals to CCG DRB	102	84
Taxpayer position accepted	54	34
Taxpayer position rejected	40	44
Taxpayer position partially accepted	1	-
Taxpayer position partially rejected	1	-
Board remitted for further work before re-referral	4	5
Board provided advice and guidance – no decision sought	2	1
Sample cases	11	10

Issues governance

We have governance processes in place to determine our approach to issues that affect multiple taxpayers in a consistent and even-handed manner. In general, policy teams refer issues to the Anti-Avoidance Board (AAB) for avoidance issues and to the Contentious Issues Panel (CIP) for other issues.

During 2022 to 2023:

• the CIP met 6 times and considered 7 issues (7 times and 6 issues in 2021 to 2022) involving personal tax and VAT
• the AAB met 5 times and considered 8 issues (6 times and 11 issues in 2021 to 2022)

One issue was referred to the commissioners from the CIP. No issues were referred to the commissioners from the AAB (one case was heard by the commissioners in 2021 to 2022).

General Anti-Abuse Rule (GAAR) and GAAR Advisory Panel

The purpose of the GAAR is to discourage taxpayers from entering into abusive arrangements, and to deter the promotion and enabling of such arrangements. The GAAR Advisory Panel is an independent body made up of experts with legal, accountancy and commercial backgrounds. It provides an early opinion on whether tax arrangements are unreasonable.

We are legally required to consider the opinions issued by the panel in reaching a final decision on whether to use the GAAR to address the tax advantage arising from the arrangements, or whether to apply penalties to enablers who facilitated the use of those arrangements. Courts must also take into account the panel’s opinion if the tax arrangements are considered by them. The panel’s opinions are published on GOV.UK to help taxpayers recognise abusive tax avoidance schemes.

In 2022 to 2023 the panel provided opinions in 6 cases (2 in financial year 2021 to 2022), of which 2 relate to the enablers regime. In all but one case the opinion of the panel has been that entering into and carrying out the arrangements was not a reasonable course of action. HMRC has now issued the first enablers penalties.

Since 2018, we have issued over 6,100 GAAR opinion notices (applying GAAR Advisory Panel opinions) to taxpayers who have used these arrangements. Taxpayers have the right to appeal against any adjustments made under the GAAR and any penalties that may be due if their case is settled under the GAAR.

Read more about the GAAR at GOV.UK.

Ensuring a standard approach to penalties for inaccuracies and failures to notify

We charge our customers inaccuracy penalties when we find that they have filed an inaccurate tax return, claim or document, and the inaccuracy occurred because of careless or deliberate behaviour on their part. We charge our customers failure to notify penalties when we find that they have not told HMRC about changes which affect their liability to tax, VAT or other duties.

We work hard to ensure consistency in our decisions to charge these penalties. We do this by maintaining effective controls to make sure decisions are considered and authorised at the appropriate level, taking into account both the size and complexity of the tax risk and the corresponding penalty.

We control penalty decision-making through line manager authorisation checks, and specific governance boards for the most complex cases. We use networks of senior tax professionals to support our caseworkers with advice and assurance.

Alternative Dispute Resolution

Alternative Dispute Resolution (ADR) in HMRC is a dispute resolution process which involves an impartial and neutral HMRC mediator actively assisting parties to work towards resolving a tax dispute outside of the tribunal or court.

Figure 44: ADR Process in HMRC

The data and information presented in this chart is available in an alternative format within the HMRC’s annual report and accounts 2022 to 2023: chart data – tab 44.

While currently, most ADR applications are made once we have made a decision and the customer has appealed, it is possible to consider ADR at any point of a compliance check. Customers can apply for ADR via telephone or online through GOV.UK. The mediator will decide within 30 days whether the case is suitable for ADR. The type of cases which are out of scope for ADR can be found in the published ADR guidance on GOV.UK. These are usually cases where ADR cannot add value to the dispute because for example legal precedent is set and HMRC does not have discretion to amend the decision. If the mediator has concerns about whether the case is suitable for ADR or whether ADR can add value, the case is referred to an internal governance panel for consideration. If we agree to enter into ADR, the mediator will work with the HMRC caseworker and the customer to try to resolve the dispute. The mediator will aim to conclude the process within 4 months. The parties in dispute have ultimate control over the decision on whether to settle.

ADR continues to have a positive impact on over 80% of the cases which are accepted into the process. In this instance, positive impact means that the case has been progressed, either by fully resolving the dispute, partially resolving the dispute or the issues in dispute and both sides’ positions have been clarified enabling them to make an informed decision on how to move forward.

The majority of mediations take place via video which helps provide greater operational flexibility and reduce costs. The ADR terms and conditions have been clarified following discussion with stakeholders and cases are now progressing under these conditions with the new Record of Outcome.

Table 14: Alternative dispute referrals

	2022-23	2021-22
Total applications for ADR (either side can propose ADR)	1,013	1,047
Cases rejected by governance panels	279 (note 1)	283
Cases rejected as being Out of Scope	268	298
Cases awaiting decision	17	25
Active cases	149 (note 2)	147
Cases resolved	326 (note 2)	269
% of cases resolved	86.7% (note 2)	80%
Cases going to litigation	73	96

Note 1: This figure does not include ‘Out of Scope’ applications.

Note 2: This figure could include applications from a previous tax year.

Settlement opportunity published in 2022 to 2023

Where multiple taxpayers are affected by a similar disputed issue, such as a tax avoidance scheme, we may publish our position on the disputed issue and invite affected taxpayers to resolve their case on the published basis. This enables us to handle such issues efficiently, with transparency and consistency.

On 11 April 2022, we published a settlement opportunity for users of remuneration trust tax avoidance schemes. The settlement opportunity was available for individuals or companies who have used certain tax avoidance schemes involving remuneration trusts. It did not apply to any individual or company under criminal investigation. It may also not have applied where an appeal related to the tax consequences of scheme use had been referred to a tribunal.

If a court rules in the future that tax is due on an alternative basis, the settlement terms will be withdrawn, and we will expect any scheme users who have not already settled to pay tax in accordance with the court’s ruling.

Read more about the settlement opportunity for users of remuneration trust tax avoidance schemes at GOV.UK.

Reviews and appeals

If a customer disputes an appealable tax decision, they can request a statutory review of the decision or appeal to the independent tax tribunal. As most reviews settle disputes, and reviews are a more cost-effective and quicker option than appeals, it can be more beneficial to customers to seek a review in the first instance. If a customer requests a review and does not agree with the outcome, they can still make an appeal to the tribunal.

All HMRC reviews and appeals are dealt with by officers who are tax, legal or accountancy professionals working in our Solicitor’s Office and Legal Services (SOLS) group.

How we review decisions

The statutory review process provides an additional opportunity to resolve disputes without the need for tribunal proceedings. Review officers are technical specialists who are not involved in making the original decisions and so provide an objective and impartial review service. Review officers check whether the decision is in line with legislation and technical guidance, policy, and practice. The review is also an opportunity to provide feedback internally to HMRC caseworkers and, thereby, improve decision making.

We carry out the review ensuring:

• a transparent review of decisions
• quality and consistency in our review conclusions
• even-handed dealing with taxpayers at review
• as many disputes as possible are resolved without tribunal proceedings

The project initiated to take forward the recommendation made by the Office of Tax Simplification to build further confidence in the impartiality of statutory reviews has made significant progress.

The work undertaken promoting statutory reviews to external stakeholders and canvassing their views continues, and the research conducted by an external agency (Ipsos Mori) on our behalf concerning customers and agents who took a decision directly to the tribunal, without first having a statutory review was concluded and published in 2022.

Read the resulting report Understanding perceptions of the statutory review process at GOV.UK.

Building on the conclusions of that research, improvements have been made to the guidance on GOV.UK and to decision letters to explain more clearly the review and appeal rights available to customers. Changes have also been made to the process by which customers can request a review, with requests now coming directly to the Review team in SOLS, demonstrating a clear separation between the reviewer and the decision-making team.

The figures reported below show a higher proportion of automated penalty decisions upheld as we are seeing a much lower incidence of appeals where COVID-19 has been the basis of the reasonable excuse given.

Table 15: Overview of outcomes of reviews

All statutory reviews	2022-23	2021-22
Dealt with in the year	40,675	40,785
HMRC original decision upheld	14,442	10,672
HMRC decision varied	4,789	2,240
HMRC decision cancelled	21,444	27,873
Percentage where original HMRC decision was upheld	36%	26%
Number dealt with where the taxpayer was not represented by an agent	37,703	38,263
Percentage dealt with where the taxpayer was not represented by an agent	93%	94%
Automated penalty statutory reviews including default surcharge cases
Dealt with in the year	36,423	36,419
HMRC original decision upheld	11,234	7,293
HMRC decision varied	4,118	1,582
HMRC decision cancelled	21,071	27,544
Percentage where original HMRC decision was upheld	31%	20%
All other reviews
Dealt with in the year	4,252	4,366
HMRC original decision upheld	3,208	3,379
HMRC decision varied	671	658
HMRC decision cancelled	373	329
Percentage where original HMRC decision was upheld	75%	77%

Appeals

Where a dispute cannot be settled by agreement, the taxpayer can appeal to the independent tax tribunal. All appeals are heard by the First-tier Tribunal (FTT). If either the taxpayer or HMRC is dissatisfied with the decision of the FTT then they can appeal to the Upper Tribunal (UT). Decisions made by the UT are appealable through the court system. The tribunals and courts are independent of HMRC and listen to both sides of the argument before making a decision.

In 2022 to 2023 the tribunal notified us of 12,332 new FTT appeals, of which approximately 14% related to late payment or late filing penalties and surcharges.

In 2022 to 2023, 7,081 appeals were settled either by formal hearing or by agreement before the hearing.

There were approximately 39,500 appeals in progress on 31 March 2023, with 34,000 of these being appeals to the FTT that have been stood over. This is, generally, where we and the taxpayer have agreed to put the appeal on hold while waiting for a decision in a related lead case that is being litigated.

The success rate recorded in table 16 below is calculated as the percentage of hearings where the decision is in our favour or substantive elements of our case succeeded.

The tax protected through litigation in the year 2022 to 2023 is £14.32 billion (£8.2 billion in 2021 to 2022). Tax protected is a measure of the tax at risk in litigation where HMRC has successfully defended its decisions. If a specific appeal is challenging an aspect of law that would have implications for a large number of cases, then the tax protected figure will include an estimate of this wider tax at risk. Tax protected in any year is usually a reflection of a small number of cases that have a large amount of tax at stake.

HMRC’s success rate for all decided appeals across all tribunals and courts was 91.8% (88% in 2021 to 2022). This increase is largely due to the FTT striking out a group of approximately 1,000 VAT appeals.

Table 16: Data relating to decided appeals

Due to the amount of data presented, only part of the table below is visible. Please use the scollbar at the bottom of the table to view the final column.

	First-tier Tribunal (2022-23)	Upper Tribunal (2022-23)	High Court (admin division) (2022-23)	Court of Appeal (2022-23)	Supreme Court (2022-23)	First-tier Tribunal (2021-22)	Upper Tribunal (2021-22)	High Court (2021-22)	Court of Appeal (2021-22)	Supreme Court (2021-22)
Total	2,021	51	1	25	6	833	54	3	27	4
Decision for HMRC	1,811	36	1	23	6	689	37	2	21	1
Decision where substantive elements of HMRC’s case succeeded	54	1	-	-	-	46	5	1	4	1
Decision for customer	156	14	-	2	-	98	12	-	2	2
HMRC success rate	92%	73%	100%	92%	100%	88%	78%	100%	93%	50%

Included in the figures above were decisions issued in a total of 49 (42 in 2021 to 2022) cases involving or related to tax avoidance, with 43 (37 in 2021 to 2022) decided wholly or partially in HMRC’s favour – protecting tax revenue of around £2.3 billion (£0.6 billion in 2021 to 2022).

Tax Settlement Assurance Programme

Since 2013, under the Tax Settlement Assurance Programme (TSAP), a specialist team, independent of operational casework, has reviewed a small sample of settled civil compliance cases to test whether we have met our own case quality standards and correctly governed decisions relating to disputes. This includes testing adherence to internal processes such as customer service requirements. We do this as part of our overall assurance programme to help drive continuous improvement in our management of tax disputes.

To improve results and enhance the professionalism of our compliance casework, in July 2020 we launched a single set of Compliance Professional Standards (CPS), aligned to the HMRC Charter, and we are strengthening our controls and assurance activities. The CPS provide the focus for our training and for building capability, and we will use them to measure and evaluate the quality of our performance, including how responsive we are to our customers.

As reported last year, in 2021 to 2022 we refocused the TSAP to enhance the assurance of our casework. The programme continues to review settled civil compliance cases to test whether we have met our own standards. The programme currently consists of testing 400 cases in 2 tranches (bi-annually) and now includes:

• focus on the governance and customer impact aspects of compliance case working, providing a more detailed understanding of these areas of our casework
• a bi-annual approach of testing cases settled in the last 6 months, which retains a real time look but also allows time between review periods to address and respond to issues, as well as share best practice
• reporting outcomes at a theme level, rather than singular case outcomes, which provides a balanced view of where we are doing well and where we want to target improvement action across our casework operation

2022 to 2023 represents the second year of this approach. We have compared findings for 2021 to 2022 and 2022 to 2023, with the results shown below.

In 2022 to 2023, 400 settled cases were reviewed, the same number that was reviewed in 2021 to 2022. The cases reviewed provide robust evidence of casework compliance across each directorate and tax regime. Internal Audit has positively validated the Assurance Team’s methodology and results. For this year our TSAP process for checking the accuracy of yield scoring was also affirmed by the National Audit Office as part of their Managing Tax Compliance audit.

In 2022 to 2023 we tested 9 standards in 400 cases, whilst in 2021 to 2022 we tested 7 standards in 400 cases. This is due to splitting the yield results into the separate scoring components of Cash Collected, Revenue Loss Prevented and Future Revenue Benefit to provide transparency and more detailed oversight of our performance against each of these themes. In 2021 to 2022 we reported our overall performance was 85%. In order to compare like for like and looking back to see how the new methodology impacts our reporting, our overall performance in 2021 to 2022 would have been 81%. We believe this offers a more transparent result across all our yield scoring components.

The chart below shows themed result averages with a comparison to the year 2021 to 2022. The themes represent the life cycle of a case, including financial impact for the customer and HMRC to fulfil its enquiry obligations. We were then able to take an average across all themes to provide a composite indicator. The comparison to 2021 to 2022 shows a decline in 5 themes and improvements in 4, with a 3% improvement in overall performance.

Figure 45: Summary of theme scoring for 2022 to 2023 and 2021 to 2022 across 9 theme areas

Area	Accuracy rate as a % 2021-22	Accuracy rate as a % 2022-23
Risk and Planning	98%	99%
Customer Contact	79%	66%
Case Progression	78%	74%
Risk Resolution	96%	92%
Penalty Action	89%	88%
Cash Collected	83%	85%
Revenue Loss Prevented	62%	85%
Future Revenue Benefit	52%	76%
No Customer Financial Impact	93%	90%
Overall Compliance Rate	81%	84%

The data and information presented in this chart is available in an alternative format within the HMRC’s annual report and accounts 2022 to 2023: chart data – tab 45.

The exceptions to our standards are spread through the cases:

• 22.5% (89/400) of the cases reviewed met or exceeded all our required governance and quality standards
• 68% (272/400) fell short of our governance and quality standards, with no financial impact on the customer
• 9.5% (39/400) fell short of our governance and quality standards with a financial impact. Of the 39 cases, 19 were identified where the taxpayer had paid too much tax. Corrective activity has since started, and we check to ensure appropriate actions are completed

There is room for improvement and, in 2021 to 2022, we introduced dedicated improvement actions, which we have continued throughout 2022 to 2023. We expect the actions taken to embed within casework activity with realised improvements in 2023 to 2024.

In addition to settlement authorisations, a small number of the largest risks require governance at a dispute resolution board (the remits of the Dispute Resolution Boards are summarised in the relevant section of the TAC report). The TSAP monitors whether cases have been decided through the correct governance board, and where cases do not require a referral to a formal case governance board confirms whether the settlement was authorised at the appropriate level. For 2022 to 2023 our checks have revealed that 80% (4/5 cases) were referred to the relevant board at the appropriate time. One case was not referred at the right time but subsequently received retrospective clearance, indicating that the right action was taken.

The following table provides a comparison of results across the 2 years.

Table 17: Two-year annual comparison of settlement authorisations

Year	2022-23	2021-22
Settlement authorised at appropriate level	91% (116 out of 128 cases)	97% (222 out of 229 cases)