Section 224 | Meaning of “tax adviser” and “client”

(1)In this Chapter “tax adviser” means—

(a)an organisation that, in the course of a business carried on by it, assists other persons with their tax affairs, or

(b)an individual who, in the course of a business carried on by the individual as a sole trader, assists other persons with their tax affairs.

(2)An organisation or individual assists another person with their tax affairs if the organisation or individual does any of the following—

(a)advises the other person in relation to tax;

(b)acts or purports to act as an agent on behalf of the other person in relation to tax;

(c)provides assistance with any document that is likely to be relied on by HMRC to determine the other person’s tax position.

(3)A person can be a tax adviser even if they are appointed indirectly (for example, at the request of someone other than their client).

(4)In this Chapter “client”, in relation to a tax adviser, means a person who the adviser, in the course of a business carried on by the adviser, assists with their tax affairs.