TSEM2020 - Enquiry work: general - potential litigation

In response to your first submission, the technical specialist will advise you whether or not the taxpayer바카라 사이트™s position should be accepted. You should advise the taxpayer of HMRC바카라 사이트™s position. If you need to refer the case again, the technical specialist may consult Solicitor바카라 사이트™s Office about the legal position. If

  • the technical specialist has received supporting advice from HMRC Legal Group, and
  • the taxpayer has been given an opportunity to consider HMRC바카라 사이트™s position based on that advice, and
  • the taxpayer still does not accept HMRC바카라 사이트™s position

you should refer the case to the technical specialist again with a view to litigation. You should do this before issuing closure notices/assessments/offer of a review.

The technical specialist will consult the relevant litigation panel for authority to proceed.