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HMRC internal manual

Technical Teams Operational Guidance

Settling the enquiry: general: by agreement

Where there are additional liabilities the underlying profits and then the liability should be agreed, as a prelude to settlement.

Where agreement cannot be reached the liability has to be determined using formal procedures as described in SIOG8000 and EM3950.

In some cases (SIOG9500), even though underlying figures have not been agreed, we may enter negotiations to sweep matters up in a global settlement.