Settlements with HMRC

Settlements with HMRC


Where HMRC believes that it is likely to succeed in litigation and that litigation would be both effective and efficient, it will not reach an out of court settlement for less than 100% of the tax, interest and penalties at stake. 

Are you considering settling with HMRC?

HMRC’s Litigation and Settlement Strategy (LSS) is the framework within which HMRC resolves tax disputes through civil law processes and procedures. It applies irrespective of whether the dispute is resolved by agreement with the customer or through litigation. 


The LSS is designed to facilitate resolution of disputes in relation to all taxes, duties and associated payments.


A key part of HMRC’s overall strategy is to help reduce the likelihood of situations arising which may give rise to a dispute. Tax disputes may be resolved either by agreement or through litigation. Where there is a range of possible figures for tax due, the terms on which HMRC will settle by agreement will also take into account which outcome secures the right tax most efficiently. 


In considering settlement terms for one dispute, HMRC will take account of the potential read across to other open or prospective disputes as well as the impact which settling the dispute could have in releasing HMRC resources to work on other disputes. 


Where HMRC believes that it is likely to succeed in litigation and that litigation would be both effective and efficient, it will not reach an out of court settlement for less than 100% of the tax, interest and penalties at stake. 


Our team of experts at Templeton Brook Witt have assisted a number of clients with their HMRC settlement. If you need assistance with negotiations and settlement with HMRC, call us for a free no obligation consultation today.


Contact us today

We can help you deal with any tax investigation through expert advice and specialist representation. Our team deals with matters ranging from individual tax disputes to large and complex multiple client cases. 

  • Formal and Informal Notices
  • Compliance Checks
  • Penalty Notices
  • Discovery Assessments
  • Voluntary Disclosures to HMRC
  • Accelerated Payment Notices (APNs)
  • Code of Practice 8 – CoP 8 Investigations
  • Code of Practice 9 – CoP 9 Investigations
  • Contractor Loan Schemes and the Loan Charge
  • DOTAS/POTAS Inquiries
  • PAYE Tax Investigations 


  • Corporation Tax Investigations
  • IR35 Disputes
  • VAT Investigations and Inspections
  • HMRC Unannounced Inspections and Visits
  • Settlements with HMRC
  • Time to Pay Arrangements
  • Statutory Reviews
  • Forensic Tax Advice
  • Tax Litigation Advice
  • Corporate Advisory
  • Private Client Advisory


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