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Official guidance
Specialist Investigations Operational Guidance

SIOG9400 · Settlement by agreement: means to fund the offer

  • SIOG9405 · Immediate available means
  • SIOG9410 · Degree of difficulty
  • SIOG9415 · Need to establish the facts
  • SIOG9420 · Regular payment on account
  • SIOG9425 · Need for advice on current assets
  • SIOG9430 · Serious means problems
  • SIOG9435 · Updated statement of assets, and so on
  • SIOG9440 · Actual or imminent insolvency
  • SIOG9445 · Instalments - general
  • SIOG9450 · Forward interest
  • SIOG9455 · Calculation of forward interest
  • SIOG9460 · Period of instalments
  • SIOG9465 · Number and amount of instalment payments
  • SIOG9470 · Company instalment offers
  • SIOG9475 · Not all cases can be resolved by instalment arrangements
  • SIOG9480 · Offers recommended for acceptance must always be realistic
  1. Settlement by agreement: means to fund the offer: contents
  2. Settlement by agreement: means to fund the offer: company instalment offers

SIOG9470 | Settlement by agreement: means to fund the offer: company instalment offers

From HM Revenue & Customs · Specialist Investigations Operational Guidance

Where Section 455 CTA tax is included in the computation of gross liability and it is anticipated that the company will qualify for relief under Section 458, the letter of offer should provide for a final instalment of the liability to be covered by the repayment.

The form of words suggested is outlined in the Appendices to the Enquiry Manual.

The date to be entered should have regard to the period needed to repay the advance. Frequently where the director is putting the company in funds in order to pay the earlier instalments the broad effect on the overdrawn director’s loan account can be anticipated.

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