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Contents

Official guidance
Compliance Handbook

CH177000 · Sanctionable conduct by tax advisers: file access notice

  • CH177010 · Overview
  • CH177020 · Power to access a tax adviser's files
  • CH177060 · Meaning of reasonable grounds to suspect
  • CH177080 · Power to access tax adviser's files from third parties
  • CH177100 · When to issue a file access notice
  • CH177110 · What are relevant documents
  • CH177120 · What are relevant documents - examples
  • CH177130 · What the file access notice must contain
  • CH177140 · Sanctionable conduct by tax advisers: file access notice: approval by tribunal
  • CH177150 · Documents and information that cannot be requested: overview
  • CH177160 · Sanctionable conduct by tax advisers: file access notice: documents and information that cannot be requested: not in a person's possession or power
  • CH177170 · Documents and information that cannot be requested: appeal material
  • CH177180 · Documents and information that cannot be requested: personal records
  • CH177190 · Documents and information that cannot be requested: journalistic material
  • CH177200 · Documents that cannot be requested: old documents
  • CH177210 · Documents and information that cannot be requested: privileged communications
  • CH177220 · Power to copy records
  • CH177230 · Power to retain records
  • CH177240 · Appeal against a file access notice: document holder is a tax adviser
  • CH177250 · Appeal against a file access notice: document holder is not a tax adviser
  • CH177260 · Appeals against a file access notice: actions available to tribunal
  • CH177270 · Penalties for failing to comply: overview
  • CH177280 · Penalties for failing to comply: time limits
  • CH177290 · Penalties for failing to comply: initial penalty
  • CH177300 · Penalties for failing to comply: initial penalty - example
  • CH177310 · Penalties for failing to comply: daily penalties
  • CH177320 · Penalties for failing to comply: daily penalties - example
  • CH177330 · Failure to comply with a file access notice: reasonable excuse
  • CH177340 · Penalties for failing to comply: offence of concealment in connection with a file access notice
  • CH177350 · Penalties for inaccuracies: Overview
  • CH177360 · Penalties for an inaccuracy: amount of the penalty
  • CH177370 · Penalties for inaccuracies: Time limits
  1. Sanctionable conduct by tax advisers: file access notice: contents
  2. Sanctionable conduct by tax advisers: file access notice: penalties for inaccuracies: Overview

CH177350 | Sanctionable conduct by tax advisers: file access notice: penalties for inaccuracies: Overview

From HM Revenue & Customs · Compliance Handbook

A person is liable to a penalty of up to £3,000 if, in response to a file access notice, the person provides a document that contains an inaccuracy.

However, the person is only liable to a penalty if:

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the inaccuracy is deliberate or due to a failure by the person to take reasonable care, the person knows of the inaccuracy at the time the document is provided but does not inform HMRC at that time, or the inaccuracy was not careless or deliberate, but the person discovers the inaccuracy sometime later and fails to take reasonable steps to inform HMRC.

The maximum penalty is £3,000 but we would only consider that amount for very serious cases of deliberate inaccuracy. Inaccuracies assessed as careless should typically attract a lesser penalty than inaccuracies assessed as deliberate.

Where a document contains more than one inaccuracy, a penalty is payable for each inaccuracy.

We will not assess a penalty for giving us an inaccurate document if the person

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tells us about the inaccuracy at the time they give us the document, takes reasonable steps to tell us about the inaccuracy if they later discover it, (before HMRC have asked about the inaccuracy).

FA12/SCH38/PARA 25A

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