Introduction and purpose

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. It is adopted in line with the Criminal Finances Act 2017 and other applicable UK law. The policy applies to all parts of the business and to everyone who acts for, or on behalf of, Taxwise Accountancy.

Scope

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.

Statement of values and approach

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.

Definitions for clarity
Tax evasion means deliberately and dishonestly seeking to avoid tax liability by deception or concealment. Tax evasion is a criminal offence.

Tax evasion facilitation means knowingly helping another person to commit tax evasion, for example by arranging or advising on transactions intended to conceal taxable supplies or income.
Tax avoidance 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.

Tax includes, but is not limited to, income tax, corporation tax, VAT, national insurance contributions and stamp taxes.

Responsibilities and governance
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. Responsibilities include:
• ensuring the policy meets legal and regulatory requirements
• maintaining appropriate procedures and controls to prevent tax evasion facilitation
• ensuring staff receive adequate training and guidance
• monitoring compliance and reporting concerns to the board

Staff and associate responsibilities
All staff and associates must:
• read and understand this policy and follow its requirements in everyday work
• complete mandatory training as required by the business
• carry out due diligence and KYC checks when onboarding clients and third parties
• refuse and report any request to facilitate tax evasion or to act outside our procedures
• cooperate with any internal enquiries about potential breaches

Client and third party due diligence
We carry out proportionate and risk based checks when taking on new clients and when instructing or engaging third parties. Checks include identity verification, beneficial ownership checks, purpose and nature of the relationship, and screening against relevant sanctions and risk lists. Where a higher risk is identified we will apply enhanced due diligence and additional approvals before proceeding.

Risk assessment and control measures
We maintain a tax evasion risk assessment which identifies areas of higher risk. Controls include:
• client and third party due diligence and ongoing monitoring
• mandatory training for staff on recognising and reporting attempts to facilitate tax evasion
• clear procedures for approving unusual transactions, payment methods and third party instructions
• written engagement terms that prohibit illegal acts and require cooperation with our compliance checks

Red flags and indicators to watch for
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 complex or unusual payment routes such as secretive offshore arrangements or repeated cash payments
• requests to falsify invoices, conceal the true nature of transactions or omit required information from tax returns
• unusually structured deals where tax is not consistent with the commercial purpose of the transaction
• pressure to bypass normal procedures or to keep transactions off the books

Reporting concerns and whistleblowing
If you suspect behaviour that may amount to tax evasion or its facilitation you must report it immediately. You can report concerns to your line manager, the compliance lead or via our whistleblowing channel. We provide a confidential reporting route and will treat reports seriously and promptly. You may also raise concerns with external authorities where appropriate. We will not tolerate retaliation against anyone who reports in good faith.

Investigation, remediation and sanctions
All reports will be assessed and, where appropriate, investigated. If an internal investigation identifies a breach of this policy we will take proportionate action which may include termination of contracts, disciplinary action, and referral to law enforcement or tax authorities. We will also review and strengthen controls to avoid repeat issues.

Record keeping and audit trail
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.

Training and awareness
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 and is provided to other staff at appropriate intervals.

Cooperation with authorities
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.

Client expectations and contractual clauses
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 and to provide full cooperation with our due diligence checks.

Consequences for non compliance by clients or associates
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.

Policy review and updates
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.

Limitations and legal note
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.

How to raise a concern or get guidance
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.

Adoption and sign off
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.

Date of issue and review date
Policy issued on 01/01/2025. 

Where to find this policy
This policy is available on the public section of our website and on the staff intranet. Copies can be provided on request.

Taxwise 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.

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.