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Chapter CH280100

Document Cited authorities 1 Cited in Related
Vincent
Published date11 March 2016
Record NumberCH280100
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

This guidance should be followed whenever a person does not agree with a decision you make during the course of a compliance check. The guidance applies to disputes over penalties in the same way as disputes over tax liabilities.

A person could disagree with

  • the need to produce information or documents that you have requested
  • the facts on which you have based your findings or your interpretation of evidence
  • your interpretation of law
  • your method of calculating tax
  • your decision about penalty behaviour or reductions for disclosure.

You must clearly set out any point(s) in dispute. This will help both sides to see:

  • what facts are likely to be relevant in resolving any open points, and
  • what information or documentation will be required to establish those facts.

Most issues can be settled by agreement when the facts have been established and the possible views presented, considered and discussed.

Working collaboratively with the person by sharing risks, remaining neutral and non-confrontational throughout the compliance check can help minimise the chances of getting into a dispute.

However, some issues cannot be settled in this way and for those cases it is important that the person recognises that they are in dispute and that you need to agree the relevant facts needed in order to resolve the dispute even if you disagree how the law applies to those facts.

This guidance...

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