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15 September 2011 / Peter Vaines
Issue: 7481 / Categories: Features , Tax , Commercial
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One size does not fit all

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Peter Vaines reports on the inevitable failure of HMRC’s revised litigation strategy

In June 2007 HMRC launched their litigation settlement strategy which may be summarised crudely as “no deals”. The idea was that if HMRC felt that they had a good case, they would pursue it to a conclusion through the courts. However, if they did not feel it was sufficiently strong they would back down. I am sure this must have happened in some cases.

Wider purpose

There was a wider purpose which was to prevent any advantage being obtained by those entering into a tax scheme and seeking some undeserved benefit by compromising the matter (ie getting something for their trouble) or at the very least delaying the payment of tax.

The point is entirely understandable—but you do not need a “strategy” for dealing with those cases; you just say no. As far as the delay is concerned, HMRC are always going on about interest being merely commercial restitution for the delay in payment (and they get

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