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HMRC internal manual

International Manual

Clearance under the agreement: Eligible for clearance

The majority of individuals would-be deemed ‘eligible for clearance’ in relation to amounts included in Cr. Where this is the case the individual would cease to have any further UK liability on those amounts in respect of the taxes specified in the agreement; Income Tax, Capital Gains Tax, Inheritance Tax and VAT. They would also cease to be liable for any amounts of interest, penalty or surcharge directly linked to those tax liabilities which were cleared.

Where liability was cleared under the agreement, then that liability was cleared for all individuals who may be liable for that tax. HMRC will not attempt to obtain tax that has been cleared under the agreement for one person by pursuing an alternative assessment route against a different person for the same tax. For example, in cases where tax is a joint and several liability such as VAT.