CH882150 - Agent operational guidance: dishonest tax agents: getting access to an agent's files: when we require an agent바카라 사이트™s files
This page and chapter are under review as the relevant content is also published in the technical guidance chapters of the Compliance Handbook, within Compliance checks factsheets and in Compliance checks guidance. If you use particular pages regularly, please email hmrcmanualsteam@hmrc.gov.uk to let us know the specific content you find useful.
You may require access to a tax agent바카라 사이트™s files to find out the full extent of the agent바카라 사이트™s dishonest conduct, and to quantify the amount of tax lost, or the potential tax loss.
If you already know the full extent of the dishonest conduct and the tax lost you do not need to get the tax agent바카라 사이트™s files. Instead, you can consider how to recover the lost tax, see CH881800, and proceed to charging a penalty for dishonest conduct, see CH883000.
You would not need the agent바카라 사이트™s files if the agent makes a full disclosure of the dishonest conduct, either before or after you have issued a conduct notice, and then either
- amends the affected clients바카라 사이트™ tax returns, or
- gives you all the information you need to recover the lost tax from the clients affected by the dishonest conduct.
The work needed to amend clients바카라 사이트™ returns, or supply you with all the information you need to recover tax from affected clients, may be carried out by an organisation rather than a dishonest tax agent. For example, where the tax agent no longer works in the organisation whose clients are affected by the dishonest conduct. In this case you would not need access to the tax agent바카라 사이트™s files.
If you need documents or information from the tax agent바카라 사이트™s clients you must use information powers under FA08/SCH36 as part of a compliance check.