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HMRC internal manual

Technical Teams Operational Guidance

Case closure: reopening settlements: payment of additional VAT

Settlements should ideally encompass all taxes and duties (direct and indirect). TTOG5345 refers to our treatment of additional VAT. If additional VAT was not accounted for before the SI settlement; if subsequently a taxpayer does pay additional VAT for the SI Investigation period, and if he/she then approaches SI to re-open a settlement he/she should be told that this cannot be done. Any additional VAT paid after the SI settlement may be deductible in the CTSA period in which it is paid. It will not be referred back to the period in which it arose. Cases of difficulty should be referred to the Teaml Leader.