Can a company director use one HMRC Form 64-8 to authorise an accountant for both personal tax and company tax? Or do you need two separate 64-8 forms?

This is a surprisingly common question for directors, owner-managed businesses and sole traders. The situation can become particularly confusing where one person is simultaneously a company director, shareholder, sole trader, employer and individual taxpayer.

For example, one person may have all of the following tax affairs:

• Personal Self Assessment

• Individual PAYE

• Tax credits, where applicable

• Sole-trader Self Assessment

• Sole-trader VAT

• Sole-trader CIS

• PAYE as an employer in the sole-trader business

• Corporation Tax for their limited company

• VAT for the limited company

• CIS for the limited company

• Employers' PAYE for the limited company

• VAT DIY Housebuilders Scheme, where applicable

So the natural question is:

If the same person is the director of the company and the individual behind the sole-trader business, why can't one 64-8 authorise the accountant to deal with everything?

This article looks at how HMRC's 64-8 authorisation works, what the form covers, how HMRC distinguishes individuals from companies, and why the answer is not simply determined by who signs the form.

What is HMRC Form 64-8?

HMRC Form 64-8, "Authorising your agent", is one of the ways a taxpayer can authorise an accountant, tax adviser or other professional agent to deal with HMRC on their behalf.

The current HMRC guidance explains that a paid agent can be a professional accountant or tax adviser and that the client must authorise the agent before the agent can deal with HMRC on their behalf. The precise authorisation method depends on the tax service involved.

Source: Authorising an agent to deal with your tax affairs GOV.UK

Form 64-8 covers a range of tax matters, including areas such as Self Assessment, Individual PAYE, Corporation Tax, VAT, CIS and Employers' PAYE, although some services now use online or digital authorisation rather than relying solely on the paper form.

Source: Authorising an agent to deal with your tax affairs GOV.UK

The important point is that a 64-8 is not simply a general document saying:

"This accountant can access everything HMRC knows about me."

Instead, the authority relates to the relevant taxpayer and the tax matters for which the agent has been authorised.

HMRC also makes clear that the authority given is limited to the relevant matters authorised.

Source: Authorising an agent to deal with your tax affairs GOV.UK

Why does an accountant need a 64-8?

When you appoint an accountant to prepare your accounts, tax returns or deal with HMRC, the accountant may need to communicate directly with HMRC.

For example, your accountant may need to:

• discuss a Self Assessment tax return;

• check information held by HMRC;

• deal with an HMRC enquiry;

• discuss PAYE records;

• submit or amend certain tax returns;

• resolve tax-account issues;

• communicate with HMRC about VAT, PAYE, CIS or Corporation Tax where the appropriate authority exists.

HMRC explains that an authorised agent can undertake a range of activities on a client's behalf, depending on the authority given and the particular tax service.

Source: Authorising an agent to deal with your tax affairs GOV.UK

The authorisation process is therefore an important part of the professional relationship between a taxpayer and their accountant.

It also means that the accountant should not need to operate by pretending to be the client.

That distinction is extremely important for security.

Is it safe to authorise an accountant through HMRC?

Generally, yes — provided you are dealing with a genuine, properly authorised and reputable professional agent and you use HMRC's proper authorisation procedures.

HMRC has a formal framework for professional tax agents. HMRC's Standard for Agents sets out expectations for tax agents and advisers in their dealings with HMRC, including integrity, professional competence, professional behaviour and protection of client information.

Source: HMRC standard for agents GOV.UK

HMRC also has registration requirements for professional tax advisers who fall within the relevant rules.

Most importantly, you should not give your personal HMRC login credentials to your accountant or anyone else.

HMRC's digital-authorisation guidance makes clear that taxpayers should not give their sign-in credentials to their agent and that agents should not use their clients' credentials to sign in to HMRC accounts.

Source: Authorise an agent for taxes that use the digital handshake GOV.UK

A professional accountant should therefore obtain access through the appropriate HMRC agent authorisation process rather than asking you to hand over your personal Government Gateway or other HMRC sign-in credentials.

One 64-8 can cover multiple tax matters — but what does that actually mean?

This is where much of the confusion begins.

The fact that the 64-8 contains many different tax categories does not necessarily mean that every category can be combined across every taxpayer or legal entity.

For example, HMRC's 64-8 contains authorisation categories covering areas such as:

• Self Assessment

• Partnership

• Trust

• Individual PAYE

• VAT

• CIS

• Corporation Tax

• Employers' PAYE

• VAT DIY Housebuilders Scheme

The form is deliberately designed so that a client can give an agent authority for several relevant tax matters.

Source: Authorising an agent to deal with your tax affairs GOV.UK

Therefore, it is perfectly reasonable for one person to have a single 64-8 covering several of their own relevant tax affairs.

But the question becomes more complicated when the person is also acting on behalf of a limited company.

Individual taxpayer versus limited company

Consider a simple example.

John Smith is:

• an individual taxpayer;

• a sole trader;

• an employer;

• the director of ABC Limited; and

• the responsible officer of ABC Limited.

John may therefore have personal tax affairs and business tax affairs.

But the fact that John controls ABC Limited does not mean that John and ABC Limited are the same taxpayer.

John's personal Self Assessment is John's tax record.

ABC Limited's Corporation Tax is the company's tax record.

John's Individual PAYE record relates to John.

ABC Limited's Employers' PAYE record relates to the company as employer.

John's sole-trader VAT registration belongs to his sole-trader business.

ABC Limited's VAT registration belongs to the company.

This distinction is fundamental.

Why does the 64-8 form ask for different information?

The 64-8 form uses different identifiers for different tax matters.

For Self Assessment, the relevant individual identification includes the National Insurance number and Self Assessment UTR.

For Individual PAYE, the individual's National Insurance number is relevant.

For Corporation Tax, company-specific information is required, including the company's registration number and Corporation Tax UTR.

This is not accidental.

HMRC is identifying the taxpayer or entity whose records are being accessed.

The same person may be the person signing the authority, but that does not necessarily mean that they are signing in the same legal capacity.

A director can sign for the individual and for the company — but in different capacities

This is perhaps the easiest way to understand the issue.

Imagine:

John Smith

Director of:

ABC Limited

John can sign an authority relating to his own personal tax affairs.

He can also sign an authority relating to ABC Limited's tax affairs because he is the company's responsible officer.

But these are two different relationships.

For John's personal authority:

John Smith is authorising the accountant in respect of John Smith's tax affairs.

For ABC Limited:

John Smith, as the company's responsible officer, is authorising the accountant in respect of ABC Limited's tax affairs.

The person holding the pen is the same.

The taxpayer being represented is not.

What HMRC says about company authority

The 64-8 process distinguishes between an individual and a company.

For a company, the authority is given by an appropriate responsible person acting for the company.

This is an important distinction.

The director does not sign the company's authority because the company's tax affairs have somehow become the director's personal tax affairs.

The director signs because they have the authority to act for the company.

This is similar to many other areas of company law and administration: the same individual can act in different capacities.

What about a sole trader?

This is where the situation becomes even more interesting.

A sole trader is not a separate legal person from the individual.

If John Smith trades as:

John Smith Plumbing

then the sole-trader business and John Smith are not equivalent to a limited company and its director.

For example, John might have:

• personal Self Assessment;

• sole-trader trading income;

• sole-trader VAT;

• sole-trader CIS;

• employees under a sole-trader PAYE scheme.

These matters may relate to the same individual/business rather than a separate incorporated legal entity.

That is fundamentally different from:

John Smith → ABC Limited

where ABC Limited is a separate company.

What about VAT?

VAT is one of the areas that causes the most confusion.

Suppose John has a sole-trader VAT registration and ABC Limited has a separate VAT registration.

Both may appear under the broad heading VAT.

But they are not the same VAT registration.

For example:

John Smith trading as Smith Plumbing

may have one VAT registration.

ABC Limited

may have another VAT registration.

The fact that both businesses are controlled by John does not turn the two VAT records into one taxpayer record.

There is also a further complication: HMRC's current guidance says that the method of authorisation depends on the particular tax service, and some tax services use online or digital authorisation rather than relying solely on paper Form 64-8.

Source: Authorising an agent to deal with your tax affairs GOV.UK

So a modern tax-authorisation process should not assume that a paper 64-8 alone provides every form of online VAT access.

What about CIS?

CIS creates the same issue.

A sole trader may have CIS obligations in their own business.

A limited company may separately have CIS obligations.

The same individual could therefore be the person responsible for two different CIS relationships.

Again, the person is the same, but the underlying business or taxpayer can be different.

The relevant CIS authorisation needs to relate to the correct taxpayer/business record.

Source: Authorising an agent to deal with your tax affairs GOV.UK

What about Employers' PAYE?

Employers' PAYE is another good example.

Suppose John employs two people through his sole-trader business.

He has an employer PAYE scheme.

Separately, ABC Limited employs five people.

ABC Limited has its own employer PAYE scheme.

There are now two employers and two PAYE relationships.

John's sole-trader PAYE scheme does not become ABC Limited's PAYE scheme simply because John owns the company.

Therefore, the accountant needs the appropriate authority for the relevant employer record.

HMRC's guidance confirms that an authorised agent dealing with Employers' PAYE can have access to employees' personal and financial information, which demonstrates why the underlying employer relationship matters.

Source: Authorising an agent to deal with your tax affairs GOV.UK

What about Corporation Tax?

Corporation Tax is perhaps the clearest example.

Corporation Tax belongs to the company.

If ABC Limited has a Corporation Tax UTR, that UTR belongs to ABC Limited.

John's personal Self Assessment UTR belongs to John.

They are two separate tax records.

HMRC's agent guidance confirms that an authorised Corporation Tax agent can gain access to the company's information and financial information.

Source: Authorising an agent to deal with your tax affairs GOV.UK

Therefore, a director should not assume that because they have authorised their accountant for their personal Self Assessment, the accountant automatically has Corporation Tax authority for their company.

HMRC's records distinguish the different tax relationships

HMRC's wider agent guidance reinforces the same principle.

HMRC explains that an agent's authority is connected to the particular tax services and client records for which the agent has been authorised. Different tax services can have different authorisation processes, including online services, Business Tax Account authorisation, digital handshakes and Form 64-8 where appropriate.

Source: Authorising an agent to deal with your tax affairs GOV.UK

This is important because agent authority is not simply a blanket permission attached to someone's name.

HMRC checks and administers authority in relation to the relevant taxpayer and tax service.

Why does HMRC's form look as though everything can fit together?

This is probably the source of the confusion.

The 64-8 is designed as a multi-purpose authority form.

So it is perfectly understandable to look at the form and think:

"If the same form contains Self Assessment, Individual PAYE, VAT, CIS, Employers' PAYE and Corporation Tax, why can't I just tick everything?"

The answer lies not only in the tick boxes but in whose tax affairs are being authorised.

The form is an authority connected to the relevant taxpayer, business or company and to the tax matters for which authority is being given.

What if the same accountant deals with everything?

That does not necessarily mean that you need only one authorisation.

An accountant can be the same agent for:

• the individual's Self Assessment;

• the individual's PAYE;

• the sole-trader VAT;

• the sole-trader PAYE;

• the company's Corporation Tax;

• the company's VAT;

• the company's CIS; and

• the company's Employers' PAYE.

The important point is that the agent can be the same while the client/taxpayer records remain separate.

Think of it this way:

One accountant does not necessarily mean one taxpayer authority.

A practical example

Imagine that Sarah is:

• an individual taxpayer;

• a sole trader;

• registered for VAT;

• registered as an employer;

• a director of Sarah's Property Services Ltd.

Sarah's personal/sole-trader affairs might include:

• Self Assessment;

• Individual PAYE;

• sole-trader VAT;

• sole-trader CIS;

• sole-trader Employers' PAYE.

Her company's affairs might include:

• Corporation Tax;

• company VAT;

• company CIS;

• company Employers' PAYE.

The accountant may deal with all of these.

But the underlying records belong to different taxpayers or business entities.

That is the distinction that matters.

So, can one 64-8 authorise both personal and company tax?

We have now reached the key question.

It is easy to understand why someone might think one form should be sufficient. The same individual may own the company, be its only director, sign its accounts, run a sole trade, have personal PAYE income and personally deal with HMRC.

The same accountant may also be responsible for all of these matters.

However, the HMRC authorisation framework distinguishes between the individual's tax affairs and the company's tax affairs.

The 64-8 can certainly cover multiple tax matters, but that does not mean one authority should be used to combine the individual's authority with the company's authority.

Therefore, where the accountant is being authorised for both the individual's personal/sole-trader affairs and a separate limited company's affairs, the practical and safer approach is to use two 64-8 authorities: one for the individual and one for the company.

For example:

64-8 — Individual / sole trader

• Self Assessment

• Individual PAYE

• relevant personal tax matters

• sole-trader VAT, where the relevant 64-8 route applies

• sole-trader CIS, where applicable

• sole-trader Employers' PAYE, where applicable

64-8 — Limited company

• Corporation Tax

• company VAT, where the relevant 64-8 route applies

• company CIS, where applicable

• company Employers' PAYE

• relevant VAT DIY Housebuilders Scheme matters

The fact that the same director signs both forms does not change the distinction. In the first authority, the person is authorising the accountant in respect of their own affairs; in the second, they are acting as the company's responsible officer.

And remember that some services now use digital or Business Tax Account authorisation rather than paper 64-8, so the exact tax service should always be checked before assuming that a 64-8 alone is sufficient.

Source: Authorising an agent to deal with your tax affairs GOV.UK

One accountant, two capacities, two sets of records

The easiest way to remember the principle is:

The person signing the authority and the taxpayer being represented are not necessarily the same thing.

A director can sign on behalf of a company.

The same director can separately sign for their personal affairs.

The signature may come from the same human being, but the legal and tax capacity is different.

This is why a professional accountant should look beyond the name of the director and identify the actual taxpayer, business or company to which each tax registration belongs.

Do not give your HMRC login details to your accountant

There is another important lesson here.

A genuine tax agent should not need to pretend to be you by using your personal HMRC login credentials.

HMRC expressly states that clients must not give their sign-in credentials to agents, and agents must not use clients' credentials to access accounts.

Source: Authorise an agent for taxes that use the digital handshake GOV.UK

Instead, the agent should use the appropriate HMRC agent services and authorisation procedures.

This provides a much safer structure: you retain control of your own login credentials, while the accountant receives the authority they actually need to act for you.

That distinction is particularly important when choosing an accountant or outsourced accounting provider.

Be careful when choosing an outsourced accounting provider

Outsourcing itself is not automatically wrong.

HMRC's Standard for Agents applies to tax agents and advisers, including those operating outside the UK, who act professionally in relation to UK tax affairs.

Source: HMRC standard for agents GOV.UK

The important question is not simply:

"Is the person in the UK?"

Instead, ask:

• Who is actually acting as my tax agent?

• Are they properly registered where required?

• Do they use HMRC's official agent-authorisation process?

• Are they subject to appropriate professional and AML requirements?

• Will they ask for my personal HMRC login credentials?

• Who will actually have access to my tax information?

• Can I identify the regulated business and the people responsible for my work?

If somebody asks you to hand over your personal HMRC login details so that they can "act as you", that should be a serious warning sign.

You should use the proper HMRC authorisation route instead.

HMRC tax agents have standards to follow

HMRC's Standard for Agents sets out expectations for tax agents and tax advisers dealing with HMRC and their clients.

It covers matters including professional behaviour, legal compliance, protection of client information and security. HMRC expects agents interacting with HMRC to meet its standards, whether or not they belong to a professional body.

Source: HMRC standard for agents GOV.UK

HMRC's Tax Agent's Handbook provides further guidance for tax agents and advisers on using HMRC services and meeting the requirements of the tax-agent framework.

Source: The Tax Agent's Handbook GOV.UK

This is another reason why taxpayers should distinguish between a genuine professional tax agent and an unknown person who simply offers to "do your tax online" using your own credentials.

Check your accountant's professional and corporate status

For company-related work, there is now another useful verification point.

Companies House has introduced the Authorised Corporate Service Provider (ACSP) framework. ACSPs are agents, such as accountants and solicitors, that have registered with Companies House to carry out specified services for clients.

Companies House states that ACSPs must be supervised by a UK Anti-Money Laundering supervisory body.

Source: List of Authorised Corporate Service Providers (ACSPs) GOV.UK

Companies House also publishes information about ACSPs so that businesses and individuals can check the status of providers.

There is also a published list of ACSPs that have ceased or been suspended, which can be relevant when checking a provider's current status.

Source: Ceased or suspended Authorised Corporate Service Providers (ACSPs) GOV.UK

For businesses dealing with company formation, identity verification, company filings and overseas-entity matters, this provides another useful layer of confidence when choosing a professional service provider.

What should you check before appointing an accountant?

Before giving someone access to your tax affairs, it is sensible to check:

• whether they are a genuine professional business;

• whether they are properly registered with HMRC where required;

• whether they use the official HMRC agent authorisation process;

• whether they have appropriate AML supervision where applicable;

• whether they are appropriately qualified or professionally regulated;

• whether the business has a real and verifiable presence;

• whether they will protect your personal and financial information;

• whether they ask you for your personal HMRC login credentials.

Most importantly:

Do not give your personal HMRC login credentials to someone simply because they call themselves an accountant, tax adviser or outsourcing provider.

A genuine professional relationship should be based on proper authorisation — not on handing over your personal login.

Why proper authorisation matters

Your HMRC records can contain extremely sensitive information.

They may include:

• income;

• employment history;

• PAYE information;

• tax returns;

• tax liabilities;

• bank details;

• company information;

• employee information;

• VAT information;

• correspondence with HMRC.

That is why choosing the right tax agent matters.

The safest approach is not to avoid using an accountant.

The safest approach is to use a properly authorised, reputable and accountable accountant and to make sure the correct HMRC authorisation is in place.

The simple rule to remember

If you remember only one thing from this article, remember this:

One accountant can act for you personally and for your company — but your personal tax affairs and your company's tax affairs remain separate.

A director does not become the company for tax-authorisation purposes simply because they own or control it.

Where appropriate, use one authority for the individual's affairs and a separate authority for the company's affairs, together with any digital authorisations required for particular HMRC services.

Looking for a UK accountant you can trust?

Choosing an accountant is not simply about finding the cheapest person who can submit a tax return.

You are giving a professional access to some of the most sensitive financial information about you and your business.

Choose a firm that operates professionally, uses HMRC's proper agent-authorisation processes, understands the difference between individual and company tax records, follows appropriate AML and professional requirements, and does not ask you to surrender your personal HMRC login credentials.

Our practice is based in the UK and provides professional accounting and tax services to individuals, sole traders, directors and limited companies. We work through the appropriate HMRC agent-authorisation processes and, where applicable, Companies House authorised-agent arrangements.

If you need help with your personal tax, sole-trader business, limited company, VAT, PAYE, CIS or Corporation Tax affairs, talk to us about your tax matters today.

Contact us for more details

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