Lee Sharpe asks whether HMRC can be trusted to act as a judge in its own cases, and considers the options in enquiry disputes.
HMRC recently published a formal consultation, ‘Improving HMRC’s Approach to Dispute Resolution’, which aims to promote standard routes to resolve any disagreement between HMRC and taxpayer, before a hearing at the tribunal and courts as a costly last resort.
This article briefly considers those alternatives and how independent they are of HMRC’s influence.
Basic process
In the course of a typical self-assessment tax return enquiry, HMRC propose to increase the taxpayer’s liability because of one or more perceived errors (and naturally, penalties may follow). If the taxpayer disagrees, they, or
