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HMRC internal manual

Technical Teams Operational Guidance

Case closure: reopening settlements: reasons

There are four main reasons why settlements may need to be re-considered:

  • the taxpayer may seek to re-open on the grounds that the settlement was harsh or excessive
  • the taxpayer may not dispute the settlement but may claim inability to pay
  • SI may wish to re-open on the case that the settlement was inadequate or flawed so that it is impossible to enforce collection
  • there may be a carry back or similar claim (see TTOG6625).