Guidance

Compliance checks: The Human Rights Act and penalties for enablers of defeated tax avoidance — CC/FS45

This factsheet is about your rights under Article 6 of the European Convention on Human Rights (HRA) when HMRC is considering charging you an enabler penalty.

• From: HM Revenue & Customs
• Published: 2 October 2018
• Last updated: 16 December 2025 — See all updates

Documents

Compliance checks: The Human Rights Act and penalties for enablers of defeated tax avoidance (CC/FS45)

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Factsheets are for guidance only and reflect HMRC’s position at the time of writing.

Published 2 October 2018

Last updated 16 December 2025 + show all updates

1. 16 December 2025

   The phone number to call for information about tribunals and how to appeal has been updated.

2. 23 June 2023

   We have updated the section 'What your rights under Article 6 mean for you when we’re considering penalties' because our appeals process has changed.

3. 10 June 2022

   We have updated the factsheet to include sections for 'if you need help' and 'our privacy notice'.

4. 2 October 2018

   First published.