TTOG5220 - Settling the enquiry: general: overall and partial settlements

An ‘Overall’ settlement is where SI deals with all the liabilities (including interest and penalties where they apply) for a taxpayer for a year or a period of years. The taxpayer either makes an offer to pay all the liabilities outstanding or these are imposed by formal procedures.

A ‘Partial’ settlement is where SI deals with only a part of the taxpayer’s overall liability for a particular period. A contract offer may be drawn up making clear that only specified sources are within the offer and that everything else has to be agreed and paid separately.