{
  "url": "https://openlegislation.uk/finance-act-2026/schedule-20/paragraph-1",
  "json_url": "https://openlegislation.uk/finance-act-2026/schedule-20/paragraph-1.json",
  "legislation": "ukpga/2026/11",
  "legislation_title": "Finance Act 2026",
  "legislation_url": "https://openlegislation.uk/finance-act-2026",
  "path": "schedule/20/paragraph/1",
  "kind": "paragraph",
  "number": "1",
  "heading": null,
  "text": "(1) A tax adviser does not contravene section 223(1) (prohibited interaction with HMRC) in any of the following circumstances—\n(a) where the adviser provides payroll, or other tax or accounting, software to a client for use in relation to the client’s tax affairs and the adviser interacts with HMRC in their capacity as such a provider;\n(b) where the adviser interacts with HMRC in relation to—\n(i) any matter relating to a duty of customs or to any provision, so far as relating to a duty of customs, made by or under the customs and excise Acts or Union customs legislation, or\n(ii) any matter relating to a duty of excise or import VAT that is connected to a matter within sub-paragraph (i);\n(c) where the adviser is a VAT representative and interacts with HMRC in their capacity as such;\n(ca) where the adviser is an IOSS representative and interacts with HMRC in their capacity as such;\n(d) where the adviser is a NI tax representative and interacts with HMRC in their capacity as such;\n(e) where the adviser is a UK representative and interacts with HMRC in their capacity as such;\n(ea) where the adviser interacts with HMRC in relation to a tax that is not payable to HMRC (such as council tax or non-domestic rates);\n(eb) where the adviser interacts with HMRC in relation to the provision of a valuation of property under section 10 of CRCA 2005 (the valuation office);\n(f) where the adviser interacts with HMRC in relation to a client who is a group undertaking in relation to the adviser;\n(g) where the adviser interacts with HMRC in relation to an appeal to a court or tribunal;\n(h) where the adviser interacts with HMRC in order to comply with an obligation of the adviser under any enactment (including this Act);\n(i) where the adviser interacts with HMRC in response to a request for information from HMRC.\n(2) In this paragraph—\n“the customs and excise acts” has the meaning given by section 1(1) of CEMA 1979 (interpretation);\n“group undertaking” has the meaning given by section 1161(5) of the Companies Act 2006 (meaning of “undertaking” and related expressions);\n“import VAT” means value added tax chargeable by virtue of section 1(1)(c) of VATA 1994 (importation of goods into the United Kingdom);\n“IOSS representative” means a person registered as an IOSS representative under Schedule 9ZE to VATA 1994 (distance selling of goods imported to Northern Ireland: special accounting scheme) (see Part 5 of that Schedule);\n“NI tax representative” has the meaning given by regulation 76(2) of the Excise Goods (Holding, Movement and Duty Point) Regulations 2010 (S.I. 2010/593) (excise duty and distance sales: NI representatives), as those Regulations have effect subject to the Excise Duties (Northern Ireland Miscellaneous Modifications and Amendments) (EU Exit) Regulations 2020 (S.I. 2020/1559);\n“UK representative” has the meaning given by section 123 (vaping product duty: UK representatives);\n“Union customs legislation” has the meaning given by section 37(1) of TCTA 2018 (minor definitions);\n“VAT representative” has the meaning given by section 48(2A) of VATA 1994 (VAT representatives).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 20 para. 1(1)(ca) inserted (17.8.2026) by The Finance Act 2026 (Registration of Tax Advisers) (Exceptions) Regulations 2026 (S.I. 2026/815), regs. 1, 2(a)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Sch. 20 para. 1(1)(ea)(eb) inserted (17.8.2026) by The Finance Act 2026 (Registration of Tax Advisers) (Exceptions) Regulations 2026 (S.I. 2026/815), regs. 1, 2(b)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in Sch. 20 para. 1(2) inserted (17.8.2026) by The Finance Act 2026 (Registration of Tax Advisers) (Exceptions) Regulations 2026 (S.I. 2026/815), regs. 1, 2(c)"
    },
    {
      "type": "I",
      "label": "I1",
      "text": "Sch. 20 para. 1 in force at 14.7.2026 for specified purposes by S.I. 2026/807, reg. 3"
    },
    {
      "type": "I",
      "label": "I2",
      "text": "Sch. 20 para. 1 in force at 18.8.2026 for specified purposes by S.I. 2026/807, reg. 4(1)(a) (with reg. 5)"
    }
  ],
  "outstanding_effects": [
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    }
  ],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2026/11/schedule/20/paragraph/1",
    "retrieved_at": "2026-10-29T08:42:24.914774+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}