Commentary

A7.112 Money laundering—tax evasion

Administration and compliance

A7.112 Money laundering—tax evasion

A7.112 Money laundering—tax evasion

As stated in A7.111, a tax adviser is not expected to be an expert in criminal law, but he would be expected to be aware of the boundaries between deliberate understatement or other tax evasion and simple cases of error or genuine differences in the interpretation of tax law and be able to identify conduct in relation to direct and indirect tax which is punishable by the criminal law. There will be no question of criminality where the client has adopted in good faith, honestly and without mis-statement a technical position with which HMRC disagrees1.

Suspicions of

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