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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Agent operational guidance: dishonest tax agents: getting access to an agent's files: overview

Once any appeal against the determination contained in the conduct notice has been confirmed in our favour, or the time limit to appeal has expired, we can seek access to the tax agent’s files.

We can also seek access to files when a tax agent has already been convicted of an offence of fraud or dishonesty in relation to tax, see CH182520.

If we already know the full extent of the dishonest conduct and the tax lost we do not need access to files, see CH882150.

We will normally make an informal approach to the person who has the files to get what we need, see CH882300.

If we need to get formal access to a tax agent’s files we can issue a file access notice to the person who holds the documents, see CH882500.

We can only use a file access notice to get documents. The kind of documents we can get are listed at CH182600. There are restrictions on the documents we can require, see CH182700. If we need information we can use our powers under FA08/SCH36.