LSS20600 | Range of non-connected specific outcomes

While resolutions may have a range of outcomes as discussed above, there are also disputes which may have discrete outcomes within a range, each of which are possible likely outcomes of litigation.

For example, in a corporation tax dispute where alternative outcomes of £100,000, £200,000 or £250,000 may be due on a single issue depending on the view of the facts taken, but no other amounts are ‘likely outcomes’.

While HMRC may decide to settle for any of these amounts (informed by the perceived likelihood of the outcome), HMRC should not settle for an amount which is not one of these ‘likely outcomes’. Factors to take into account include:

• the absolute amounts determined by each alternative

• whether there is the possibility of precedent value in choosing one alternative over another