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HMRC internal manual

Compliance Handbook

Dishonest tax agents: appeals against a penalty: who is entitled to appeal

There are two types of penalty that we can consider charging. They are

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

Any person who has the tax agent’s working papers, for example a former employer, can be subject to a file access notice, and therefore can be charged penalties for failing to comply with a file access notice. Such a person might, for example, be a company or a limited liability partnership. The person charged with the penalty is entitled to appeal.

Penalties for dishonest conduct can only be charged on an individual, the tax agent, and so do not apply to companies or partnerships.

The Appeals, Reviews and Tribunals Guidance, contains full guidance on the review and appeals process, see ARTG2100+.