LSS20200 - Purpose and scope of the strategy

The Litigation and Settlement Strategy (LSS) is the framework for resolving tax disputes through civil law procedures. The LSS covers the lifecycle of a dispute and therefore applies from the very beginning of any compliance activity - after risk assessment has taken place.

The term ‘tax’ includes all taxes, duties, interests, and penalties.

The purpose of the LSS is to:

• ensure that we resolve disputes consistently within the law, whether by eventual agreement or through litigation where an agreement cannot be reached, and
• facilitate resolution of disputes in relation to all taxes, duties and associated payments, therefore the term ‘tax’ should be interpreted accordingly.

The LSS applies to all tax disputes resolved through civil procedures and to all decisions we take about such disputes, at whatever level.

The LSS does not apply to cases handled through criminal proceedings.