TTOG5225 | Settlement by agreement: general: 'overall' and 'partial' settlements: Code 8 and 9

It will be unusual for a Code 9 settlement to be a partial settlement.

Some Code 8 cases will likewise conclude fully. In other Code 8 cases the focus of SI interest may be narrow. It might be a particular transaction, benefits for a group of employees, revision of unacceptable accountancy treatment or whatever. In these cases - which are typically substantial corporate cases - it may be undesirable or impractical for SI to attempt to deal with the whole liability of a year or a period of years.

Care has always been important in partial settlements. There must be no ambiguity about what is within the settlement and what is outside its scope. There must be no prejudice to HMRC’s overall position.

We also have to make sure with Self Assessment in mind that the interests of other parts of HMRC are not compromised by us initiating or concluding our enquiry in such a way that their ability to make the enquiries which they wish to make is compromised