Readers are advised that HMRC have made changes to the above guidance as a result of feedback received. HMRC also advise that the relevant factsheet is also intended to be updated accordingly.

The changes are intended to clearly reflect that HMRC can only proceed to ask for documents, charge a penalty and publish details once the conduct notice appeal stage has been exhausted and, if the conduct notice is appealed, HMRC has had its decision confirmed by the tribunal.

Routine changes to the operational and technical guidance will continue to be made as required. Recent updates are shown in the update index on the HMRC website.