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HMRC internal manual

Compliance Handbook

Agent operational guidance: dishonest tax agents: publishing details of dishonest conduct: telling an organisation that we are considering publishing information about them

If it is necessary to clearly identify an individual, you can publish information about an organisation they work, or have worked, for.

There is a risk of reputational damage to an organisation if HMRC publishes information about its connection to a dishonest tax agent. You must be certain that it is necessary to publish information about an organisation.

The only information you can publish is the

  • organisation’s name
  • position in the organisation that the individual holds or held.

For example, you are considering publishing the details of John Smith who worked as a tax manager for a large firm of accountants in the Midlands. You might decide that the only way to distinguish this John Smith from others with the same name is to publish the firm’s name and Mr Smith’s position in the firm.

You must tell the individual whose details you are considering publishing that you are also considering publishing information about an organisation. At the same time, you must tell the organisation that you are considering publishing information about them.

You must give the organisation at least 30 days to make representations to you, see CH186150.

You can use letter TA11 in SEES Forms and Letters to tell the individual about details you are considering publishing.