Working with Tax Agents: Dishonest Conduct - ATT comments

The Association is pleased to have the opportunity to comment on this consultation.

The ATT comments, sent to HMRC on 15 September 2011, on revised draft legislation which will enable HMRC to tackle tax agents who act dishonestly in tax matters.

Our submission and the consultation document to which it refers are available here in Adobe (pdf) format.


The main questions raised by HMRC in the consultation are:

  • Question 1: HMRC welcomes views on the revised definition of a tax agent.
  • Question 2: HMRC welcomes views on moving away from the terminology of 'deliberate
    wrongdoing' to 'dishonest conduct'.
  • Question 3: HMRC welcomes views on the revised definition of 'loss of tax'.
  • Question 4: HMRC welcomes views on any issues about moving to a 'not exceeding'
    penalty, including the level of the penalty.


Technical Team

15 September 2011