Wherever possible, it is always best to try and resolve enquiries and disputes with HMRC through managed discussion and settlement. Where this is not possible, more formal options are available to try to unlock the dispute.
Initially, you can request that the disputed matter can be reviewed internally by HMRC. The ‘internal review’ will be conducted by a reviewer not previously involved with the case and who is usually from HMRC Solicitors Office.
Most cases in our experience can be resolved after internal review by HMRC. If however there is still disagreement, you can proceed and take the dispute forward either to mediation (ADR) or failing that, the Tax Tribunal.
Using ADR can provide a way to bring a dispute to a resolution, saving time and the expense of proceeding to the Tribunal. If you are in a protracted dispute with HMRC over a tax issue, we can support you to firstly establish whether the matter in dispute is relevant for ADR and if so, through the ADR process itself to help you achieve a satisfactory outcome.
Disputes that can’t be settled with HMRC can go to review or the Tax Tribunal.
- Internal review by HMRC is a cost-effective option
- ADR can be used to try and settle cases without using the Tax Tribunal
- The First-Tier Tax Tribunal offers independent resolution
