Paragraph 66
(1)
HMRC and the appellant may agree that payment of an amount of tax should be postponed pending the determination of the appeal.
(2)
The agreement may modify a determination by HMRC under paragraph 64.
(3)
Where the agreement does so, it is to be treated in the same way as a settlement agreement under paragraph 61.
(4)
The consequences of an agreement are to be the same as if the tribunal had, at the time when the agreement was entered into, made a direction to the same effect as the agreement.
(5)
The existence of an agreement does not preclude a further determination by HMRC or direction by the tribunal modifying the agreement.
(6)
An agreement—
(a)
must be made in writing;
(b)
may be made with a person acting on behalf of the appellant in relation to the appeal.