CH178010 | Sanctionable conduct by tax advisers: conduct notice: overview

If we have gathered sufficient evidence to determine on the balance of probabilities that a tax adviser is engaging in, or has engaged in, sanctionable conduct, we may issue a conduct notice. An authorised officer must approve the decision to issue a conduct notice.

A conduct notice states our determination that the tax adviser is engaging in, or has engaged in, sanctionable conduct. It gives tax advisers a final opportunity to provide information to demonstrate that they have not engaged in sanctionable conduct before we issue a penalty.

FA12/SCH38/PARAS 25B and 25C