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From 30 September 2017, if someone in your firm facilitates tax evasion and you don’t have reasonable prevention procedures, you could be faced with unlimited fines, not to mention reputational damage.
The Criminal Finances Act 2017 introduces a new corporate failure-to-prevent offence relating to the facilitation of tax evasion. This is supported by HMRC guidance, centering around six core principles that should inform your prevention procedures. It’s all very reminiscent of the Bribery Act regime but with subtle differences just to keep you on your toes, eg ‘adequate’ prevention procedures becomes ‘such prevention procedures as was reasonable in all the circumstances to expect’.
It’s not jus
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