Amit Puri reviews HMRC action against third parties including agents and advisers – or the lack of it…
We recently asked HMRC for statistics and information on penalties and other sanctions they could and should have levied on deserving third parties for bad behaviour. We wanted to gauge both HMRC’s powers and appetite in the pursuit of advisers.
We acknowledged that HMRC can and do raise tax assessments on people even where they have taken ‘reasonable care’ with their own tax affairs. However, this was in cases where the errors/irregularities were due to the ‘careless’ or ‘deliberate’ actions of someone other than them. We asked how many such instances there were in the past five years, annually?
We also acknowledged that HMRC can and do issue penalties on persons other than the taxpayer, where those persons had ‘deliberately’ caused inaccuracies or withheld information. We asked how many such instances there were in the past five years, annually, and the value of the penalties? These penalties will have been charged under Paragraph 1A of Schedule 24 to the Finance Act 2007.
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