LSS20100 - Litigation and Settlement Strategy: Overview

HMRC’s Litigation and Settlement Strategy (LSS) is the framework within which HMRC resolves tax disputes through civil law processes and procedures in accordance with the law. It applies irrespective of whether the dispute is resolved by agreement with the customer or through litigation. For more information, see the Litigation and Settlement Strategy (LSS) - GOV.UK.

The LSS helps us to decide:

  • whether the LSS applies to the dispute
  • whether we should pursue a dispute
  • how we should handle it, and
  • how we should resolve it

The guidance that follows expands on these points. For more guidance on

  • the purpose and scope of LSS, see LSS20200
  • what a dispute is, see LSS20300
  • minimising the scope for a dispute, see LSS20700
  • deciding whether to pursue a dispute, see LSS20800
  • handling a dispute, see LSS30100 and
  • resolving a dispute, see LSS40100

Where relevant, other manuals may contain more detailed guidance about the key points in a compliance check where you must consider them alongside this guidance. For example, see the Enquiry Manual (EM), Appeals, Reviews and Tribunals Guidance (ARTG), Compliance Operational Guidance (COG), and so on.