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HMRC internal manual

Technical Teams Operational Guidance

Settlement by agreement: general: all offers to be formally considered

Usually offers are invited and are made to the Commissioners of Revenue and Customs, after a negotiation process which gives them a realistic prospect of acceptance, but a taxpayer cannot be prevented from making an offer, even if it is clearly deficient, or precedes the conclusion of the investigation.

The process of case closure is described in TTOG6000. When an unacceptable offer is received the settlement report procedure described there should be modified and reduced to a brief report. The Investigator should recommend rejection and when confirmation has been received the taxpayer should be informed that the offer has been considered but cannot be accepted. Further action will depend on the circumstances and stage of the case.

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