
HMRC have published additional guidance regarding the authorisation of multiple and specialist agents.
Following the revision to the form 64-8 (Agent authorisation) in 2006, HMRC have been asked for clarification regarding a number of situations which do not appear to be dealt with by the new form, such as where a client has multiple agents for the same tax regime, or where an agent is appointed solely for a specific transaction.
The guidance indicates that, in most cases, the client will need to authorise the agent(s) by way of a letter to HMRC, explaining the respective responsibility of the agent(s).
The reverse of form 64-8 states “If you have more than one agent (for example, one acting for the PAYE scheme and another for Corporation Tax), please sign one of these forms for each.” But what happens when two agents act for one client on different aspects of the same tax regime?
HMRC acknowledge that it is not unusual for an accountant who is dealing with the day-to-day self assessment matters to sub-contract enquiry work to a self assessment enquiry specialist. Businesses may decide to use more than one agent to handle different aspects of their VAT or employer PAYE affairs too, for example with one agent handling the day-to-day VAT matters and another dealing with a VAT appeal.
HMRC's internal IT systems are not set up to send different types of outputs to multiple agents, and that sort of customisation is unlikely to become available in the near future. Therefore, manual arrangements are in place to deal with multiple agents, to ensure that existing client/agent data is not removed from all the IT systems by the appointment of a specialist agent to carry out a specific task.
In practice, this guidance means that taxpayers should notify HMRC in writing and specify which matters may or may not be disclosed to the specialist.
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