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<p>Disputes with taxpayers of all types as to the right amount of tax that is due
are a normal part of tax administration. There is huge variation in the nature of
tax disputes depending on the complexity of the taxpayer’s behaviour, the amount and
type of tax at stake and the transactions undertaken. Under its statutory powers,
HM Revenue and Customs (HMRC) resolves most civil tax disputes by agreement and without
resorting to litigation where the settlement secures the tax that HMRC believes is
due under the law. If the right amount can’t be agreed, the dispute goes to litigation
at the Tribunal. For any dispute, HMRC’s decision on how it should be resolved is
taken by the final appropriate decision maker with appropriate management oversight.
For the majority of cases this will constitute authorisation by a case worker’s line
manager. However, the most significant and sensitive cases are considered by three
Commissioners.</p>
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