Section 85(3)

Where an agreement is not in writing— the preceding provisions of this section shall not apply unless the fact that an agreement was come to, and the terms agreed, are confirmed by notice in writing given by HMRC to the appellant or by the appellant to HMRC, and references in those provisions to the time when the agreement was come to shall be construed as references to the time of the giving of that notice of confirmation.

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Source: legislation.gov.uk · retrieved 2026-07-28