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HMRC internal manual

Oil Taxation Manual

PRT: administration: appeals against claim decisions - abandonment of appeal

Abandonment of Appeal by a Notice in Writing - OTA75\SCH5\PARA5(3)

It may happen that, although an appeal remains unresolved in one remaining item, the company presses for an amendment to be made to the appropriate assessment to give effect to the remaining expenditure now agreed. Such a request should receive due consideration. If the circumstances are exceptional, for example the expenditure still in dispute is small in relation to that agreed on appeal and there are problems in resolving the open issue which are not due to any delay or lack of co-operation by the company, the request may be accepted.

Where therefore, at an early stage in the examination of a claim, it appears that an item of expenditure will lend itself to some protracted dispute, a separate decision disallowing this item can be given which isolates the item on a separate appeal leaving other expenditure to be dealt with in a separate decision or decisions and free from the possible problem referred to above.