Originally posted by ChimpMaster
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Agreement is you and HMRC agreeing the final liability. That can be by agreement or imposed by a Judge.
Everything else in this space is an interim measure designed to accelerate money flows (APN) or frustrate justice and the system of taxpayer protections (loan charge) or apply a liability that is unsupported in law or Court (settlement). I count these are largely obstacles to agreeing the final position.
What is more, obstacles that absorb time, confuse people and allow HMRC convenient hiding places.
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