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HMRC internal manual

Compliance Handbook

Dishonest tax agents: how to process a penalty: overview

We will issue a penalty assessment when a person has become liable to

  • a penalty for failing to comply with a file access notice, see CH183300+, or
  • a penalty for dishonest conduct, see CH184040+.

We can only issue a penalty assessment for a penalty for dishonest conduct where we have already issued a conduct notice, see CH182100+, and any appeal rights against the notice, see CH182160, have expired or been exhausted.

We will tell the person

  • how we calculated the penalty
  • what they owe, and
  • when and how they must pay it.

There are time limits for issuing a penalty assessment. The enforcement rules that apply to income tax also apply to the penalty assessment.