[CH182540] Dishonest tax agents: file access notice: power to access tax agent's files
There are two situations where we are able to obtain tax agent's files. They are known as Case A and Case B situations.
Case A situation
Case A situations are where we have issued a conduct notice, see CH182140, and any appeal rights against that notice have either expired or been exhausted.
Case B situation
Case B situations are where the individual has been convicted of an offence relating to tax that involves fraud or dishonesty, and the offence was committed after the individual became a tax agent. It does not matter whether they were still a tax agent when they committed the offence, and it is regardless of the capacity in which they committed the offence.
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