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HMRC internal manual

Specialist Investigations Operational Guidance

Settlement by agreement: means to fund the offer: number and amount of instalment payments

It is undesirable for administrative reasons to have instalments that exceed four per annum. The frequent payment of small sums should be discouraged.

There is scope for considerable flexibility in the agreement of an instalment arrangement, particularly where we are reassured by a significant initial payment, the granting of a legal charge over assets and (where appropriate) a joint and several offer, and so on.

The instalments may be end loaded, with differential instalments, where there is a severe initial difficulty but the expectation of asset realisation or enhanced profits to come.