HMRC Alternative Dispute Resolution: Expert Witness Support UK

HMRC's Alternative Dispute Resolution (ADR) process can prove a useful springboard into non-litigation routes to resolution. It is often worth fully engaging with the HMRC internal review process even where the initial decision appears adverse, as this can sometimes resolve the dispute without tribunal proceedings.

In HMRC ADR, the tax expert witness can provide a preliminary technical opinion that informs the ADR position, establishing the strength of the taxpayer's case before committing to the FTT route. This also helps in quantifying the exposure and informing settlement negotiations.

Early expert instruction before ADR ensures the technical tax analysis is robust and can be deployed effectively in mediation. Where ADR does not resolve the dispute, the expert's preliminary analysis forms the foundation for the FTT expert report.