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For an overview of the concept of reasonable excuse, see A4.568.

The commentary below is concerned with the common practice whereby the taxpayer entrusts some or all of their tax affairs to an accountant, solicitor or other professional tax adviser and whether reliance on such a person can constitute a reasonable excuse. Such professional advisers are often described generically as agents, since they have authority to deal with HMRC on the taxpayer's behalf. Reliance upon third parties in other contexts is considered in A4.568D.

Note that this article does not discuss reliance on an adviser in the context of whether the taxpayer has taken reasonable care in relation to an inaccuracy penalty. That commentary can be found at A4.532A.

For reliance on an adviser in cases of late notification of an appeal to the Tribunal, see late appeals section at A5.602.