Conclusion 20

Disputes between HMRC and large businesses over how much tax is owed can be resolved either through settlement or litigation. HMRC’s decisions on whether to settle are framed by its litigation and settlement strategy, which states that HMRC will not settle for less than it could reasonably expect to get through litigation. HMRC has a range of governance processes in place to minimise the risk that tax disputes with large businesses will be settled on terms overly favourable to businesses. This includes the use of governance boards to ensure that there is a separation of powers between those working on an investigation and those approving a settlement. HMRC tests that it is consistently adhering to these governance arrangements through its tax assurance settlement programme and through the large business directorate’s quality assurance programme. HMRC does not report the results from its quality assurance programme publicly, and so Parliament can only rely on the results of the tax assurance settlement programme to Parliament to get reassurance tax disputes are dealt with fairly and consistently. In 2024–25, this programme only examined 20 disputes involving large businesses. Of these, four were referred to a governance board and HMRC followed the correct processes in all four cases.31