INTM820520 | Clearance under the agreement: Amounts not cleared: Applicable rates of tax, assessment periods, etc
From HM Revenue & Customs · International Manual
Where amounts were not cleared, then the usual tax rules applied to unpaid liabilities. This included rates of tax, interest, penalties and assessment time-limits.
However, it was possible for those uncleared amounts to fall within the terms of a facility (such as the Liechtenstein Disclosure Facility), so long as the relevant qualifying conditions were otherwise met.