On 1 February 2023, UK HMRC published Alternative Dispute Resolution (ADR) Guidance with details of an alternative dispute resolution procedure. ADR in HMRC is a flexible process in which an impartial and neutral HMRC mediator actively assists parties in working towards resolving a tax dispute outside of the Tribunal or Court. The parties in dispute have ultimate control of the decision to settle. ADR can be used before and after HMRC has issued a decision that can be appealed against, and at any stage of an enquiry, including:
- During a compliance check, when both parties are unable to reach an agreement, or where progress in the enquiry has stalled; and
- At the end of a compliance check, when a decision has been made that the customer can appeal against, once the appeal has been made.
