On 3 December 2012, the Government announced additional investment in HMRC to clamp down on tax avoidance and evasion.
Since the announcement, HMRC are inviting some participants in certain schemes to settle their tax liabilities by agreement, without the need for litigation. HMRC believe that this settlement opportunity offers both the taxpayers and HMRC the best opportunity to resolve these disputes in a way which is cost-effective and consistent with the law.
Where people decline the settlement opportunity, HMRC will increase the pace of their investigations and accelerate disputes into litigation.
HMRC are aiming to contact all those who are eligible for the offer by the end of January 2013.
The settlement opportunity is made in accordance with HMRC’s Litigation and Settlement Strategy. HMRC will advance all available arguments if disputes are litigated. As well as continued uncertainty, delay in resolution, additional costs and potential reputational damage, taxpayers who choose the litigation route may end up with a worse tax result than they would obtain under the settlement opportunity.