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HMRC internal manual

Specialist Investigations Operational Guidance

Settlement by agreement: means to fund the offer: need to establish the facts

Because the seriousness of means problems varies so much it is essential to establish the true facts so that we can make a proper response. This may mean testing out what we are told.

The earlier that cases with severe means problems are identified the better chance we have of achieving a fair and equitable settlement. It therefore follows that we should have asked questions in advance of the settlement stage of an investigation so as to be aware that a taxpayer has a means problem.