Litigation and Settlements Strategy

Issued on 6 June, in what can only be described as a low key manner, and without even so much as a banner or a date, the Revenue has published its Litigation and Settlements Strategy (LSS). The LSS can be downloaded here.The accompanying release asserts, inter alia, that the "aim of the LSS is to ensure that we conduct disputes in a way which is professional, effective and that supports HMRC's objectives to close the tax gap and provide customers with a clear understanding of the law."

There is much that could be said about the sentiment, but providing customers with a clear understanding of the law ! Who exactly writes and approves this drivel, and do they have any first hand experience of the woefully poor knowledge of the law now routinely displayed by the Revenue's own under trained and demotivated staff ?

One can but speculate over what the typical Revenue employee (stuck at the coalface, with nowhere near enough education to deal properly with the demands of their job, and having to put up with the increasing resentment of the professional agents forced to spend their own time and money on correcting Revenue errors) feels when reading such a pronouncement by their very own employer ?

Turning to the strategy statement itself, this is certainly worth a read, and with a highlighter pen at the ready. The statement is not unreasonable if read only in the context of the "top end" issues dealt with by the upper echelons of the Revenue, but the statement does not state such a context. Because of this, it would appear fair game to resort to using the statement when dealing with any Revenue dispute, and to pick any number of the choice snippets provided and to fire these straight back at the Revenue.