CH176180 - Sanctionable conduct by tax advisers: who is a person
For the purposes of dealing with tax advisers who engage in sanctionable conduct, a tax adviser can be either an individual or an organisation. A tax adviser, or former tax adviser, can be charged a penalty for sanctionable conduct.
In addition to referring to tax advisers, this guidance also refers to ‘persons’.
A person in this guidance includes the tax adviser who engages in sanctionable conduct, but also includes any other person or entity in relation to third party file access notices.
FA12/SCH38 as amended