Statutory / Internal Review

The Statutory, or Internal Review is an HMRC-led mechanism whereby another Tax Inspector, not previously involved with the case, can consider matters. A Statutory Review can be a very useful method of resolving a dispute, particularly where it seems that the tax investigator is misinterpreting the key facts, or applying the tax law incorrectly.

Tax Tribunal

If a case does proceed to a Tribunal hearing we will consider whether appropriate Counsel should be instructed and, if so work closely with them to achieve the best outcome possible.

Alternative Dispute Resolution

Where the relationship with the investigating HMRC officer has broken down, then the ADR route can be useful to move things forward.  This is usually adopted prior to the Statutory Review or appeal to the Tax Tribunal.  A so-called independent HMRC employee “facilitator” is used to try and restore the communication process and accelerate the settlement of the case.  The HMRC facilitator cannot decide the outcome of any dispute.  They can simply advise both sides on the best way to break the log-jam and progress matters and can be a useful route if you feel the compliance officer is not listening to you or is misunderstanding you.

The  Adjudicator and Ombudsman

The Adjudicator and The Ombudsman are two different offices (independent of HMRC), and are there to help taxpayers who are unhappy with how the taxman is treating them.  They can investigate complaints, and award compensation.  They are pretty much a last resort, and are really only appropriate where HMRC are acting unreasonably.  It is important to note that these are not the best forums for resolving disputes about key facts.