In previous years I filed several returns where we did not hold a 64-8.
There is a FAQ on HMRC's website suggesting you do now need to be authorised as an agent:
"As an agent, can I send tax returns online for my clients?
Yes, but you'll need to be authorised to act on their behalf. "
So seems like the situation is different this year?
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depends on which software you use but the answer is basically ye
third party software you can file anyones tax return
HMRC apply for an online authorisation code under client services? when you log into SA ( i think this is what they are talking about)