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HMRC internal manual

Compliance Handbook

Dishonest tax agents: publishing details of tax agent dishonest conduct: inviting representations

We may decide not to publish the tax agent’s name and other details even where the penalty for dishonest conduct is more than £5,000.

To be fair and consistent, we will always aim to publish where the tax agent has incurred a penalty for dishonest conduct of more than £5,000 but we recognise that there may be exceptional circumstances where publication of some or all of the details are not appropriate. For example, it may not be appropriate to publish any information where to do so would

  • prejudice a criminal investigation, or
  • cause a serious and verifiable risk to the person’s safety.

Where we decide that publication is appropriate we will

  • tell the tax agent that we intend to publish their name and other details, and
  • give them a reasonable opportunity to make representations, see CH884300.

Making representations is an opportunity for the tax agent to provide reasons why we should not publish some or all of the details. Normally we will allow 30 days for the tax agent to make representations although this period may be extended if there is good reason. We will consider all representations carefully and take them into account in deciding whether to publish.

Where we decide to publish information about an organisation where the tax agent works or worked, we will tell that organisation of their intention and give them reasonable opportunity to make representations, CH884400.


FA09/S94 (6)