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HMRC internal manual

Appeals reviews and tribunals guidance

Reviews and appeals for direct taxes: Settlement of appeals: By agreement

Appeals may be settled by agreement before, during or after review and at any time before any decision is made by the tribunal. Where the appeal is settled following review, see ARTG4830 and ARTG4840.

Where the appeal is settled after the customer has notified the appeal to the tribunal, see ARTG8460.

If HMRC and the customer agree that the decision or assessment should either be upheld or varied in a particular manner, the decision maker or if appropriate the review officer, must always confirm any verbal agreement with the customer in writing (s 54(3) TMA 1970).

Note: An appeal settled by agreement has the same effect as if the appeal were decided by the tribunal, so the decision maker should take care when drafting any agreement. And they should also take legal and/or specialist advice if the agreement could affect tax treatment in later years.

After reaching an agreement the customer has 30 days from the date of the agreement (or written confirmation of a verbal agreement) to notify us in writing that they have changed their mind (s 54(2) TMA 1970).