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HMRC internal manual

Compliance Handbook

CH179380 - Sanctionable conduct by tax advisers: other penalty issues: double jeopardy

A person is not liable to a penalty for sanctionable conduct where that person has been convicted of a criminal offence in respect of the same matter.

However, concealing, destroying or otherwise disposing of required documents relating to file access notices, see CH177340, which results in prosecution, will not preclude a sanctionable conduct penalty.

FA12/SCH38/PARA33