Our commitment to the highest standards of ethical conduct and compliance with the Criminal Finances Act 2017
Taxwise Accountancy has a zero tolerance approach to tax evasion and the facilitation of tax evasion. This policy sets out our values and the practical steps we take to prevent anyone acting for or on our behalf from criminally facilitating tax evasion, whether in the UK or abroad.
This policy applies to all employees, directors and officers, agency staff, contractors, consultants, secondees, interns, temporary workers and volunteers, and to all third parties who act for or on our behalf, including agents, partners, suppliers and clients.
Wherever we refer to associates in this policy, that term covers the groups listed above. The policy applies to all parts of the business.
We will act professionally, fairly and with integrity in all business dealings.
We will not tolerate tax evasion, or the facilitation of tax evasion, by any person or organisation connected to our business.
We require those who act for or on our behalf to follow the same standards.
Means deliberately and dishonestly seeking to avoid tax liability by deception or concealment. Tax evasion is a criminal offence.
Means knowingly helping another person to commit tax evasion, for example by arranging or advising on transactions intended to conceal taxable supplies or income.
Means using legal methods within the law to reduce tax. Tax avoidance is not illegal, but we will not support aggressive schemes that seek to abuse the system.
Includes, but is not limited to, income tax, corporation tax, VAT, national insurance contributions and stamp taxes.
Overall responsibility for this policy rests with the board and senior management of Taxwise Accountancy. Day to day responsibility for policy implementation sits with our nominated compliance lead.
All staff and associates must:
We carry out proportionate and risk-based checks when taking on new clients and when instructing or engaging third parties.
Identity Verification
Confirming who the client is
Beneficial Ownership
Understanding who controls the entity
Purpose & Nature
Understanding the relationship
Risk Screening
Sanctions and risk list checks
Enhanced Due Diligence: Where a higher risk is identified we will apply enhanced due diligence and additional approvals before proceeding.
We maintain a tax evasion risk assessment which identifies areas of higher risk. Controls include:
Client and third party due diligence and ongoing monitoring
Continuous review of relationships and transactions
Mandatory training for staff
Recognising and reporting attempts to facilitate tax evasion
Clear approval procedures
For unusual transactions, payment methods and third party instructions
Written engagement terms
That prohibit illegal acts and require cooperation with compliance checks
Employees must be alert to unusual circumstances that may indicate a risk of tax evasion or facilitation. Examples include:
Customers or associates who insist on secretive offshore arrangements or repeated cash payments
Requests to falsify invoices, conceal the true nature of transactions or omit required information from tax returns
Deals where tax treatment is not consistent with the commercial purpose of the transaction
Pressure to bypass normal procedures or to keep transactions off the books
If you suspect behaviour that may amount to tax evasion or its facilitation you must report it immediately.
Your Line Manager
Discuss concerns with your immediate supervisor
The Compliance Lead
Contact our designated compliance officer directly
Whistleblowing Channel
Use our confidential reporting route for sensitive matters
External Authorities
You may also raise concerns with external authorities where appropriate
Protection Guarantee: We provide a confidential reporting route and will treat reports seriously and promptly. We will not tolerate retaliation against anyone who reports in good faith.
All reports will be assessed and, where appropriate, investigated. If an internal investigation identifies a breach of this policy we will take proportionate action.
Termination of Contracts
With non-compliant parties
Disciplinary Action
Against employees involved
Legal Referral
To law enforcement or tax authorities
We will also review and strengthen controls to avoid repeat issues.
We provide regular training on this policy, the Criminal Finances Act 2017 and how to spot and report suspicious requests.
Training is mandatory for staff whose role exposes them to tax risk
We keep records of client due diligence, risk assessments, approvals for unusual transactions, staff training and reports of suspicious activity. Records are retained in line with our data retention policy and legal obligations.
Accurate record keeping helps prevent tax evasion and supports any subsequent enquiries or investigations.
We will cooperate fully with any lawful request from tax or law enforcement authorities, including HMRC. Where appropriate, we will disclose relevant documents and information to assist official enquiries.
We will only act for clients who are willing to provide the information we need to comply with legal and regulatory obligations. Our engagement letters and contracts include clauses that require clients and associates to:
Comply with applicable tax laws
Provide full cooperation with our due diligence checks
Consequences for Non-Compliance: If a client or third party refuses to provide required information, or if checks reveal unacceptable risk, we will decline or terminate instructions. Where we reasonably suspect criminal facilitation of tax evasion we will consider reporting to the appropriate authorities.
This policy is reviewed regularly and at least annually to ensure it reflects legal and regulatory changes and the evolving nature of our business. The company may update the policy at any time and will communicate changes to staff and associates.
Policy Issued:
01 January 2025
Next Review:
January 2026
If you need advice about this policy or want to report a concern, please contact our compliance lead using the contact details on our website.
Reports will be handled confidentially and without retaliation.
Contact UsTaxwise Accountancy is committed to the highest standards of ethical conduct. We expect our people, clients and partners to share our commitment and to help prevent tax evasion and any attempt to facilitate it.
This policy was approved by the board of Taxwise Accountancy and takes effect from the date published on our website. It is mandatory for all staff and associates.
This policy is an internal company policy. It does not replace any legal advice. It summarises the company approach but is not a contract. Nothing in this policy prevents Taxwise Accountancy from complying with its legal duties or from cooperating with regulators and law enforcement.
This policy is available on the public section of our website and on the staff intranet. Copies can be provided on request.
If you would like a tailored anti tax evasion statement for a client agreement or a staff training pack based on this policy, contact us via the details on our website.
We can help your business implement robust compliance procedures and training programs.