There will be no let up in the HM Revenue & Customs' litigation and settlement strategy (LSS), announced in 2007, and aimed at reducing tax avoidance by setting consistent standards for the way the department settles disputes.
Speaking at a seminar on tax disputes yesterday evening, Anthony Inglese, general counsel and solicitor at HMRC, said that the strategy, which allows for no 'deals' with the Revenue, was having an effect on the avoidance market.
HMRC always welcomed feedback, he said, but added that companies should 'note the determination of HMRC to press ahead with the strategy'.
He said that before the formulation of its LSS - which was aimed at unifying the former Inland Revenue and Customs & Excise different strategies for settling disputes - 'customers' felt they could 'go for it' and try different avoidance schemes, and settle any disputes as part of a 'packaged' deal.
'This is a strategy for the long haul,' said Inglese, who heads the 400-strong office responsible for all legal services to HMRC.
Introducing the LSS in 2007, Dave Hartnett, former HMRC director general, business, said that the LSS 'ensures that where we are confident about the strength of our case and the disputed point is a significant one, we will insist on 100% of the tax or other liabilities that HMRC believes to be due.
'Where we accept that we do not have strong grounds for our position or the issue is less important to us, we will aim to avoid disputes altogether.'
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