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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 are not cleared, then the usual tax rules apply to unpaid liabilities. This includes rates of tax, interest, penalties and assessment time-limits.

However, it is 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 are otherwise met.