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HMRC internal manual

Compliance Handbook

Dishonest tax agents: conduct notice: appeal against decision to issue conduct notice

A tax agent can appeal to HMRC against our determination contained in a conduct notice. They then have the right to a review and may notify their appeal to the tribunal instead of, or after, a review.

The notice of appeal must

  • be in writing
  • be given to the officer who issued the conduct notice
  • be within 30 days from the date on which the conduct notice was issued, and
  • state the grounds for the appeal.

The tribunal can confirm or set aside our determination that the tax agent is engaging, or has engaged, in dishonest conduct.

If the tribunal sets aside the conduct notice, this does not prevent a further conduct notice being issued in respect of the same conduct if further evidence emerges.

The appeal follows the direct tax process for appeals. The Appeals, Reviews and Tribunals Guidance contains full guidance on the review and appeals process, see ARTG2100+.