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Official guidance
Litigation and Settlement Strategy

LSS40000 · Resolving a dispute: content

  • LSS40100 · Resolving a dispute: overview
  • LSS40200 · Resolving a dispute: Disputes must be resolved in accordance with the Law
  • LSS40300 · Resolving a dispute: How dispute resolution is put into effect must be in accordance with the Law
  • LSS40400 · Resolving a dispute: no package deals
  • LSS40500 · Resolving a dispute: All or nothing disputes
  • LSS40600 · Resolving a dispute: Dispute where there may be a range of possible figures
  1. Resolving a dispute: content
  2. Resolving a dispute: All or nothing disputes

LSS40500 | Resolving a dispute: All or nothing disputes

From HM Revenue & Customs · Litigation and Settlement Strategy

An ‘all or nothing’ issue is one which has only two possible outcomes: either a given amount is due or it is not.

Where a dispute relates to an all or nothing issue you must not accept any out of court resolution that splits the difference.

Sometimes a dispute that initially appears to be an all or nothing issue may turn out to be one where there is a range of possible figures. Wherever an issue initially appears to be all or nothing, you should explore (preferably with the person) whether or not:

  • there is a range of right answers for how the law should be applied to the facts, or

  • the issue can be broken down into two or more sub-issues, each of which can be resolved separately

  • See the examples at LSS50000.

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