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HMRC internal manual

Specialist Investigations Operational Guidance

Settlement by agreement: means to fund the offer: immediate available means

Ideally offers should be ‘full offers’, that is in an amount that covers the full duty outstanding, interest (where due) and penalties (where applicable).

In many cases a taxpayer has liquid resources sufficient to fund immediate payment of the full normally computed offer.

Where this is so, there should be no question of deferred payment or instalments. The offer obtained should be a ‘cash offer’, payment to be made by a specified date within a month, or 30 days after the date of the letter notifying acceptance of the offer.