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HMRC internal manual

International Manual

Clearance under the agreement: Amounts not cleared: Applicable rates of tax, assessment periods, etc

Where amounts were not cleared, then the usual tax rules applied to unpaid liabilities. This included rates of tax, interest, penalties and assessment time-limits.

However, it was possible for those uncleared amounts to fall within the terms of a facility (such as the Liechtenstein Disclosure Facility), so long as the relevant qualifying conditions were otherwise met.