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HMRC internal manual

Compliance Handbook

Dishonest tax agents: determining dishonest conduct: overview

When we determine that a tax agent has engaged in dishonest conduct we will issue them with a conduct notice.

‘Dishonest conduct’ is where the tax agent does something dishonest with a view to bringing about a loss of tax revenue in the course of assisting clients with their tax affairs.

It does not matter whether there is an actual loss of tax, or whether the tax agent is acting on the instructions of the client.

Sanctions can be imposed where a ‘tax agent’ engages in ‘dishonest conduct’.

The following guidance explains

  • the determination, see CH181110 
  • what is dishonest conduct, see CH181120, and
  • the meaning of dishonesty, see CH181140.

Operational guidance gives examples of what we consider to be dishonest conduct at CH880200 and has guidance on how we establish dishonest conduct at CH881000+.

FA12/SCH38/PARAS 2 - 3