I am in the process of concluding an enquiry with HMRC....
Figures for the tax understated have been suggested and I've negotiated them downwards.
My client does not accept the adjustments, but wishes to put the matter behind him and move forward. I have explained that there are week areas in the record keeping and he should therefore reach a settlement with HMRC based on the latest figures suggested.
The problem is that the inspector will not agree the amount of the penalty (or the interest, although I can estimate this) until my client has agreed the figures. Is he within his rights to so this. Being sceptical I think he'll now load the penalty to recover some of the tax he has lost in the negotiations!
Is my client now entitled to make an offer (a contact settlement?)
This is a CTSA enquiry.
Thank you for your help.