CH178320 - Sanctionable conduct by tax advisers: penalty for sanctionable conduct: disclosure: giving access
Giving access includes a tax adviser responding reasonably promptly and accurately (taking into account their abilities and circumstances) to requests for information and documents and allowing access to information and documents.
Access is needed for us to make sure that the information disclosed is complete. What is important is the timing, nature and extent of the access given.
The timing is relevant because a person should give access when requested and there should rarely be a need for us to issue reminders for our file access notices, see CH177010. If it is not possible to produce the records or relevant documents at the time of the request the person should give reasons and make reasonable efforts to provide them as soon as reasonably possible.
The nature of the access is important. The person should offer access to their records and documents in a convenient and agreed manner. If we require copies these should be provided where possible. If we encounter difficulties in getting access, then this should be reflected in the quality of the disclosure.
The extent of the access given covers what records and documents are made available. Generally, the tax adviser would know what records and documents exist or can be obtained and it is for them to tell us. If records or documents that the person has within his or her power or possession are not offered, then this would be reflected in the quality of disclosure.