Internal investigation on suspicion of failure to prevent tax evasion—checklist

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Checklists

Internal investigation on suspicion of failure to prevent tax evasion—checklist

Published by a ��˾��ҹ�� Corporate Crime expert

Checklists

This Checklist explains the issues which should be considered when advising on and undertaking an internal investigation into whether the corporate criminal offence of failure to prevent the criminal facilitation of tax evasion has occurred. It should be read in conjunction with Practice Notes: Failure to prevent the criminal facilitation of tax evasion—the offences and Self-reporting corporate offences as well as the Failure to prevent the facilitation of tax evasion toolkit.

Initial considerations

Oversight

The top-level management of an organisation should be committed to preventing persons acting in the capacity of a person associated with it from engaging in criminal facilitation of tax evasion. They should foster a culture within the organisation in which tax evasion facilitation is never acceptable. Consider:

•
has the company appointed an officer of sufficient seniority responsible for compliance and oversight of the company’s risk assessment, and policies and procedures in respect of preventing the facilitation of tax evasion?

Internal reporting/whistleblowing

An important aspect of an effective strategy to prevent the facilitation of tax evasion is having an established

Jurisdiction(s):

United Kingdom

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