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 âwithout prejudiceâ does not mean that it will be held to be such. If it is evidence of a âtax factâ then it may be able to be used in future litigation.
Where a document affects the customerâs tax liability and the customer wishes to proceed to litigation following the conclusion of ADR, the mediator will make such documents readily available to HMRCâs legal teams before litigation.