13.Paragraph 4 applies if HMRC determine that a person has engaged in dishonest conduct.
14.Sub-paragraph (2) and (3) provide that an authorised HMRC officer may notify the person of that determination, stating the grounds (a conduct notice).
15.Sub-paragraph (4) sets out the implications of a conduct notice by reference to later paragraphs of the Schedule (tribunal authorisation of a file access notice and a penalty for dishonest conduct).
16.Paragraph 5 provides a right of appeal for the tax agent against HMRC’s determination of dishonest conduct, setting out the procedure and what the tribunal may do.
17.Paragraph 6 provides for a criminal offence if a person disposes of a material document which could otherwise be sought under a file access notice.