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HMRC internal manual

Fraud Civil Investigation Manual

HM Revenue & Customs
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Where CDF offer is made 30 June 2014 onwards: penalties and settlement of cases: settlement

For direct taxes, where agreement is reached and it is administratively more convenient for both the customer and HMRC, settlement is normally reached through contract settlement. Where agreement cannot be reached, or you consider that this would be less resource intensive, you should proceed formally and make any assessments or determinations.

Indirect tax cases are settled by making assessments.