Commentary

A6.419A Use of deeds in settling tax enquiries

Administration and compliance

A6.419A Use of deeds in settling tax enquiries

A6.419A Use of deeds in settling tax enquiries

Enquiries may be settled by:

  1.  

    •     formal closure notice (see A6.418A),or

  2.  

    •     deed, or

  3.  

    •     contract settlement, see A6.420

If the taxpayer is prepared to agree with the officer's findings, he is usually invited to enter into a contract settlement (see A6.420). In some cases, however, HMRC will propose using a deed to settle the enquiry by agreement, or the taxpayer may insist on the use of a deed1.

If the taxpayer does not agree with the amount of tax underpaid or is unwilling to enter into a contract settlement, the procedures described

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