CH176140 | Sanctionable conduct by tax advisers: Commencement date

We can only charge penalties for sanctionable conduct under this guidance where the sanctionable conduct occurs on or after 1 April 2026.

However, we can issue a file access notice after 1 April 2026 requesting documents that existed before 1 April 2026. We can request these earlier documents to allow us to determine whether the test for sanctionable conduct is met. This may include, for example, seeking records to confirm that a person is acting as a tax adviser for a taxpayer where that relationship began before 1 April 2026.

This legislation amends Schedule 38 to the Finance Act 2012. We can charge penalties for dishonest conduct by tax agents prior to 1 April 2026, see CH180000.