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HMRC internal manual

Debt Management and Banking Manual

Debt and return pursuit: PAYE: Regulation 72 (5) Income Tax (Pay As You Earn) Regulations 2003: appeals: settling the appeal

Agreement under Section 54 TMA 1970

An appeal can only be settled under Section 54 (1) TMA 1970 if both sides agree and if so, the case will be as if determined by the Tribunal. Written agreement or written confirmation of an oral agreement is required here, so there has to be an exchange of letters for a valid agreement.

However, under Section 54 (2) the appellant can reject this agreement within a 30-day “cooling-off” period. You should draw this to the appellant’s attention if they do not have an agent or solicitor.