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United KingdomGOV.UK

HMRC revises the procedure for settling instalment offers early

Officials must refer early settlements to TALA with the original offer and acceptance. Separate guidance still requires a varied offer letter when settlement figures are reopened for adjustment.

By Taxxa AI OyPublished 25 August 2026

Tax

Industry: Across industries

HMRC now directs officials to contact TALA to enable early settlement of a direct-tax instalment arrangement, enclosing the original letter of offer and letter of acceptance.GOV In its early-settlement guidance, this replaces wording requiring a varied offer letter when a contract settlement was reopened to alter instalment terms.GOV

The accompanying relief instructions now apply wherever the processes in EM6412 to EM6414 apply. Previously, their opening condition referred to a valid claim to reopen a settlement. Officials must still recalculate the expected offer, agree the reduction with the taxpayer or agent and check payments already made. They must contact TALA with the original offer and acceptance to administer those processes.GOV

There remains a distinct requirement for cases involving adjustment of settlement figures. EM6413 continues to require a varied offer letter when a settlement is reopened.GOV It also requires the underlying relief claim to satisfy the relevant conditions and statutory time limits: settling by contract does not permit a claim that could not have been allowed against an assessment. General dissatisfaction with the original liability calculation is not an accepted ground for reopening.

HMRC encourages customers who can clear their instalment balance or make a substantial cash payment to do so. It allows a proportionate reduction of the addition for time granted, with the precise calculation depending on the circumstances. Officials check the payment history with the SAFE nominee and recalculate that addition. A substantial payment that leaves some liability outstanding also requires recalculation of the remaining payment dates.

The linked forward-interest guidance distinguishes contract settlements agreed on or after 8 May 2026 from earlier agreements.GOV The revised early-settlement method applies to the former, with forward interest applied only to the interest-bearing amountGOV; earlier contracts use the previous method in place when agreed.

The relief calculation also retains a restriction where HMRC originally accepted a sub-standard offer because of limited means: relief is reduced by the amount of that original shortfallGOV. After recalculation, the treatment depends on payments and the remaining liability. Amounts already paid may warrant repayment, while a remaining balance not immediately due is dealt with by cancellation rather than repayment.

These contract-settlement instructions cover direct tax and expressly exclude VAT and VAT penalties.

HMRC sets out early settlement of instalment offers in Enquiry Manual EM6414 and the method of giving relief in EM6415.

Before arranging early payment, check the settlement agreement date and payment history and ask HMRC to confirm the recalculated amount needed to settle.

Sources