LSS20700 - Minimising the scope for a dispute

HMRC’s Charter defines the standard of service and behaviour that customers should expect when dealing with us. We try to support our customers to fulfil their obligations and pay the right tax without the need for a dispute.

Therefore, the starting point of the Litigation and Settlement Strategy (LSS) is to reduce the scope for disputes to arise. Open and early dialogue between HMRC and the customer we are checking may allow a difference of views about situations or transactions to be identified and addressed.

This may include explaining to the person:

• what we are checking
• why we are checking it
• what could be wrong and why
• our assessment of the identified risks.

By explaining this as soon as we start a compliance check our aim is to resolve uncertainty and eliminate any potential disputes about these matters. In some cases, sharing risk information before we open a compliance check may encourage the person we are dealing with to submit correct returns without the need for further enquiry.

If a dispute still arises, see the following guidance at LSS20800 onwards.