EM6336 - Contract Settlements: Letters of Offer: Detail - Consideration
The guidance about contract settlements at EM6000+ only relates to direct tax. You must never include VAT or VAT penalties in a contract settlement.
In English law a contract normally requires consideration to make it binding - the taxpayer바카라 사이트™s offer to pay is matched by HMRC바카라 사이트™s agreement not to take any further proceedings.
Scottish contract law does not have this requirement but it is still desirable to set out the consideration in a Scottish offer.