Taxes Management Act 1970 section 54

Settling of appeals by agreement

Section 54 deals with the process by which a tax appeal can be settled by agreement between the taxpayer and HMRC, without the need for a tribunal hearing.

• An agreement between the appellant and HMRC to uphold, vary or cancel an assessment has the same legal effect as a tribunal decision
• The appellant has a 30-day cooling-off period during which they can withdraw from the agreement by giving written notice
• Any oral agreement must be confirmed in writing before it takes effect, and the agreement is treated as made on the date of that written confirmation
• If the appellant notifies HMRC they wish to withdraw the appeal and HMRC does not object in writing within 30 days, the assessment is treated as upheld without variation