INTM820400 - Clearance under the agreement: Not eligible for clearance
In certain circumstances, although individuals may have opted to incur the one-off charge, they would have been deemed not eligible for clearance. In these cases, the one-off payment would have been calculated in the same way, but would have been treated as a credit allowable against the UK tax liabilities of the individual.
Circumstances where individuals were deemed not eligible for clearance are considered further within the Other Terminology section of this guidance (INTM840200).