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HMRC internal manual

Compliance Handbook

Dishonest tax agents: other penalty issues: double jeopardy

We cannot charge the tax agent with a penalty for dishonest conduct where that agent has been convicted of a criminal offence in respect of that dishonest conduct.

However, concealing, destroying or otherwise disposing of documents relating to dishonest conduct, see CH182180 and CH183420, which results in prosecution, will not then preclude the dishonest conduct penalty.

FA12/SCH38/PARA33