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HMRC internal manual

Specialist Investigations Operational Guidance

Settlement by agreement: means to fund the offer: company instalment offers

Where Section 455 CTA tax is included in the computation of gross liability and it is anticipated that the company will qualify for relief under Section 458, the letter of offer should provide for a final instalment of the liability to be covered by the repayment.

The form of words suggested is outlined in the Appendices to the Enquiry Manual.

The date to be entered should have regard to the period needed to repay the advance. Frequently where the director is putting the company in funds in order to pay the earlier instalments the broad effect on the overdrawn director’s loan account can be anticipated.