ECL33400 - Appeals and reviews: settling appeals by agreement

HMRC may settle an appeal by way of agreement in writing, a “settlement agreement” between the appellant and HMRC. This must be:

(a) entered into before the appeal is determined, and

(b) to the effect that the decision appealed against should be upheld without variation, varied in a particular manner, discharged, or cancelled.

If the settlement agreement in entered into in relation to an appeal, the consequences are to be the same as if the tribunal had decided the appeal and upheld the decision without variation.

This does not apply if, within 30 days beginning with the date on which the settlement agreement was entered into, the appellant gives notice in writing to HMRC that they wish to withdraw from the agreement.