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HMRC internal manual

Specialist Investigations Operational Guidance

Settlement by agreement: means to fund the offer: serious means problems

If it seems likely that there are sufficient funds to make a full offer, albeit maybe allowing a short time to realise assets and build up liquidity, then matters can be left to be resolved at the settlement meeting.

If the problem is more serious and there are real doubts whether the taxpayer can make a full offer even with instalments then work needs to be done before the settlement meeting.

An instalment offer is only a full offer where not only does it incorporate full duty, interest and penalties but also an amount representing ‘forward interest’. (See SIOG9450).

(This content has been withheld because of exemptions in the Freedom of Information Act 2000) TTOG6250(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

A contract offer should not be taken for less than the tax owing. In such circumstances the proper approach is to proceed by way of assessment or determination. See SIOG9500 in cases where the tax loss is not precisely quantified.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)