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Our litigation and settlement strategy provides the framework within which HMRC seeks to resolve tax disputes through civil procedures. 聽Guidance on the role of Tribunals is set out at ARTG (external users can find the guidance at /hmrc-internal-manuals/appeals-reviews-and-tribunals-guidance/artg8660).聽 The appeal process enables both sides to develop their arguments and seek to resolve the dispute but, if they can鈥檛 reach agreement, they can present those arguments to an independent body.聽 In many cases, the decision isn鈥檛 clear cut and both parties put forward 鈥渞espectable鈥� arguments.聽 It doesn鈥檛 necessarily mean that the losing party has made a mistake if their argument is not supported by the Tribunal.

Costs can be settled through assessment by the Tribunal or through negotiation with HMRC Legal Group. These costs will run from the date of the decision/review that gave rise to the appeal. 聽The Tribunal may award or the HMRC Legal Group聽may reach an agreement 聽to pay costs less than the actual cost incurred, e.g. the customer incurred professional fees of 拢5000 in connection with the dispute and following the Tribunal 鈥榮 assessment or the negotiated settlement the customer receives 拢4000.聽 The customer may appear to be out of pocket by 拢1000, but there will be good reason why the full amount is not awarded or agreed in settlement .聽 Our redress policy does not allow us to reimburse the balance of 拢1000.聽 We can, however, consider 鈥減re appeal鈥� costs.聽 See CRG5500.