This article was originally published by inCOMPLIANCE
Keily Blair, Kirsty O’Connor and Becky Rodwell ofer some advice on the implementation of “reasonable prevention procedures” to prevent the facilitation of tax evasion.
Since 30 September 2017, organisations can be held strictly liable if any of their associated persons (including employees) criminally facilitate the evasion of tax either in the UK or overseas. The only defence companies can rely on is that they have reasonable procedures in place to prevent the facilitation of tax evasion.
Although the Criminal Finances Act 2017 (the “Act”) came into force last year, many compliance officers are unclear about what “reasonable prevention procedures” means for their organisation. The attached article, originally published by inCOMPLIANCE explains what the new offences are, draws on our experience of working with clients across the tax and legal disciplines to help them navigate the new offences, and outlines some common approaches we are seeing compliance teams take.
