EM6003 | Contract settlements: overcoming delay
From HM Revenue & Customs · Enquiry Manual
The guidance about contract settlements at EM6000+ only relates to direct tax. You must never include VAT or VAT penalties in a contract settlement.
If a customer does not make an acceptable offer within a reasonable timeframe
you can proceed using formal powers
consider the penalty position
keep the customer updated whilst also setting out you are open to further discussion regarding a contract settlement
You may revert to settling the case by way of contract at any time prior to giving the relevant notice which concludes the formal compliance activity.