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Home / Simons-Taxes /Administration and compliance /Part A6 Enquiries, compliance checks and investigations /Division A6.3 HMRC powers /Tax agents—dishonest conduct / A6.323 Power to obtain papers
Commentary

A6.323 Power to obtain papers


Administration and compliance

HMRC has power to require access to an agent's working papers where either1:

  1. Ìý

    (1)ÌýÌýÌýÌý a conduct notice has been issued (see A6.322) and:

    1. Ìý

      –ÌýÌýÌýÌý any appeal has been withdrawn

    2. Ìý

      –ÌýÌýÌýÌý the right of appeal has been exhausted, or

    3. Ìý

      –ÌýÌýÌýÌý the time allowed for an appeal has expired, or

  3. Ìý

    (2)ÌýÌýÌýÌý the individual has been convicted of a tax offence involving fraud or dishonesty after he became a tax agent (whether or not he was still an agent when the offence was committed, and regardless of the capacity in which it was committed) and:

    1. Ìý

      (i)ÌýÌýÌýÌý any appeal has been withdrawn

    2. Ìý

      (ii)ÌýÌýÌýÌý the right of appeal has been exhausted, or

    3. Ìý

      (iii)ÌýÌýÌýÌý the time allowed for an appeal has expired, and

    4. Ìý

      (iv)ÌýÌýÌýÌý 12 months has elapsed since the date on which (i)–(iii) was satisfied

Tribunal approval

In either case the Tribunal must approve the giving of a written file access notice2, but it will do so only where3:

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Web page updated on 17 Mar 2025 14:21