LSS10000 - How to use this guidance

This guidance explains some detail about HMRC’s Litigation and Settlement Strategy (LSS). The full text of the LSS is available on GOV.UK HMRC’s Litigation & Settlement Strategy

The Litigation and Settlement Strategy (LSS) and this guidance describe a holistic approach to compliance work and no one paragraph or sentence should be read in isolation or taken out of context from the overall approach described. This is practical guidance for HMRC staff on the application of the LSS.

It is designed to provide context and background to the LSS. While it can also be used for reference when considering individual paragraphs of the LSS, users are encouraged to read the whole document. When considering how to resolve disputes, it is especially important that the whole of paragraphs 16 -19 of the LSS are read together.

A key part of HMRC’s overall customer strategy is to help reduce the likelihood of situations arising which may give rise to a dispute. Disputes are costly for both HMRC and its customers, therefore HMRC is committed to supporting its customers to get their tax right without the need for a dispute.

This guidance applies to all civil tax compliance work across HMRC but does not aim to be comprehensive, nor will every element of it be applicable in every case. Further information on how HMRC resolves civil tax disputes and our governance framework can be found here GOV.UK - How HMRC resolves tax disputes.

Special considerations might apply to the resolution of disputes involving, for example:

  • National Insurance Contributions (NICs), where a dispute may affect an individual’s contributory record as well as the amount of contributions payable
  • Pay As You Earn (PAYE), where the outcome of a dispute may affect an employee’s tax liability
  • Value Added Tax (VAT), where the outcome of a dispute may affect others in the supply chain.

This is not an exhaustive list, therefore you should read this guidance alongside any other detailed operational and policy guidance that applies to your case.