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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: Non Contract Settlements: Introduction

Where any disputes arise, or you reach an impasse, you should first consider whether Alternative Dispute Resolution (ADR) may help you and the taxpayer resolve these. See the ADR web pages for guidance about ADR.

Where you are still unable to agree amounts, you will need to conclude matters formally.


For assessments raised after 5 April 1998 (with the exception of 1996/97 partnership assessments) SA interest rules apply and will be automatically charged.

However, for assessments raised on or before 5 April 1998 (and for all 1996/97 partnership assessments whenever raised) you should consider making TMA70/S88 interest determinations.


Where you consider that the omissions are culpable EM5100+ you should refer to the penalty determinations guidance EM5200+.


When an enquiry is settled by way of assessment rather than by contract, you should advise Debt Management and Banking (DMB) about

  • possible collection difficulties EM3955+
  • any general payment on account to be set against the final liability EM3965.