Six steps to fend off ‘failure to prevent’ tax evasion charges
By Will Grahame-Clarke, 18 May 18
A law firm outlines how financial advice firms can protect themselves from the criminal offence of failing to prevent tax evasion.
Principle 2 – Proportionality of risk-based prevention procedures
To be ‘reasonable’, prevention procedures must be proportionate to risks. Procedures are expected to evolve with the relevant body’s activities and the risk climate.
Principle 3 – Top level commitment
Procedures must demonstrate the commitment of top-level management to prevent engagement in the facilitation of tax evasion and to foster an atmosphere in which it is unacceptable.