Note that with effect from 1 April 2013 this legislation is superseded by new powers for HMRC to take action against those tax agents it determines as having engaged in dishonest conduct, see ´¡6.321–A6.323.
A tax accountant is defined as a person who has assisted another person (the taxpayer) in the preparation or delivery of tax1 returns, information, accounts or other documents which he knows will be, or are likely to be, used for tax purposes2. The definition therefore extends to other professionals including lawyers.
Notwithstanding the protection for the working papers of an auditor or tax adviser described in A6.310, documents may be demanded3 from a tax accountant who has been
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