As a firm, we value our reputation for ethical behaviour and financial probity. We do not tolerate tax evasion or the criminal facilitation of tax evasion in any circumstances, whether committed by clients, our personnel, or those who perform services for or on behalf of the firm.
The Criminal Finances Act 2017 introduced two corporate criminal offences for failing to prevent the criminal facilitation of tax evasion: one relating to UK tax evasion and one relating to foreign tax evasion. These offences may apply where an associated person (such as an employee, agent, contractor or other service provider) criminally facilitates tax evasion while performing services for or on behalf of the firm.
We are committed to preventing the facilitation of tax evasion and maintain reasonable prevention procedures designed to mitigate this risk. Our prevention framework is informed by HMRC guidance and includes:
- Risk assessment
- Proportionate risk-based procedures
- Top level commitment
- Due diligence on associated persons and relevant third parties
- Communication and training
- Monitoring and review
We provide regular training to our personnel and take appropriate disciplinary action where misconduct is identified. We also undertake due diligence on relevant third parties and include appropriate contractual protections where suitable. Our procedures are kept under review and updated to reflect changes in risk, working practices, and relevant guidance.
Chris Schwer, Senior Partner