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Under the Criminal Finances Act 2017 (CFA 2017), an organisation commits an offence when the following conditions are satisfied:
criminal tax evasion by a taxpayer under existing law
criminal facilitation of that tax evasion by an associated person of organisation A who is acting in the capacity of an associated person
failure of organisation A to prevent the associated person committing the facilitation act
There are two different offences which differ based on whether the tax is evaded in the UK or in a foreign country.
Since the definition of a person who is acting in the capacity of a person associated with a relevant body is broad in scope and embraces employees and agents of the rel
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