IHTM36335 - Letters of offer: consideration
In English law, a contract normally requires consideration to make it binding - thetaxpayer’s offer is matched by HMRCs agreement not to take further proceedings.Scottish contract law does not have this requirement, but it is still considered desirableto set out the consideration in a Scottish offer.
Where extra time is being allowed for payment, and an additional ‘interest’charge (IHTM36253) is being made the words ‘and the timegranted� should be added after ‘hereby offer in respect of the (duties,)(interest) (and) penalties�.