ADRG02000 | Record of documents exchanged during ADR

All documents exchanged during the ADR process are treated in the same way as any other information sent to HMRC and are on the formal record.

Marking a document as “without prejudice” does not mean that it will be held to be such. If it is evidence of a “tax fact” then it may be able to be used in future litigation.

Where a document affects the customer’s tax liability and the customer wishes to proceed to litigation following the conclusion of ADR, the mediator will make such documents readily available to HMRC’s legal teams before litigation.