CIOT has responded to HMRC’s second consultation on the introduction of a corporate criminal offence of failure to prevent the criminal facilitation of tax evasion. We take the view that the offence must be applied proportionately and appropriately if it is to be effective.
Finance (No2) Act 2015 s 50 places notification obligations on persons who give offshore advice or services. Regulations have not yet been published. We will be issuing guidance for members as soon possible.