HMRC Consultation: Working with tax agents: dishonest conduct - LITRG response

Published on 16 September 2011

LITRG welcomes the opportunity to respond to this consultation and HMRC’s efforts to engage with representatives and make amendments to the proposals since the last consultation on ‘deliberate wrongdoing’. Our previous concerns were that the draft legislation was far too broad and could have caught situations such as well-meaning friends or family seeking to help others, and volunteer advisers in the tax or general advice charities (or other pro bono capacity).

Our response makes just two points on the draft legislation. Firstly, it would be helpful to specify that charitable organisations are excluded from the scope of the legislation and secondly, that the ‘file access notice’ provisions should be qualified to state that HMRC’s belief that another person holds relevant documents must be ‘reasonable’.

To see the full LITRG response please use the link below:

PDF icon HMRC consultation: Working with tax agents: dishonest conduct – LITRG response


Contact: Kelly Sizer (please use form at