Anti-Tax Evasion Policy Writers

What are Anti-Tax Evasion Policies?

Anti-tax evasion policies set out how organisations prevent, identify and respond to risks of tax evasion and the facilitation of tax evasion.

Tax evasion is a criminal offence that can expose organisations to serious legal, financial and reputational damage.

A clear policy ensures that employees, contractors and business partners understand their responsibilities and that robust procedures are in place to comply with UK law.

What Do Anti-Tax Evasion Policies Cover?

An anti-tax evasion policy typically includes:

• A statement of zero tolerance towards tax evasion and the facilitation of tax evasion

• Definitions and examples of tax evasion and facilitation offences

• Responsibilities of staff, managers and contractors in preventing tax evasion

• Due diligence requirements for suppliers, clients and business partners

• Procedures for identifying and reporting suspected tax evasion

• Training and awareness for employees on recognising risks and red flags

• Disciplinary action for employees found to have engaged in or facilitated tax evasion

• Cooperation with HMRC and other authorities as required

• Links to anti-bribery and corruption, anti-money laundering, financial crime and procurement policies

A clear policy helps employees understand what constitutes tax evasion, how to avoid involvement, and the steps to take if they suspect wrongdoing.

It also ensures compliance with the Criminal Finances Act 2017, which introduced corporate offences for failing to prevent the facilitation of tax evasion.

By embedding strong anti-tax evasion practices, organisations can reduce legal risks, protect their reputation and demonstrate their commitment to lawful and ethical business conduct.

Legal Basis

The principal duty is the Criminal Finances Act 2017, which created two corporate offences: failure to prevent the facilitation of UK tax evasion and failure to prevent the facilitation of foreign tax evasion. The defence is "reasonable prevention procedures".

HMRC's guidance sets out the six guiding principles (risk assessment, proportionate procedures, top-level commitment, due diligence, communication and training, monitoring and review).

Common Compliance Pitfalls

• Risk assessment treated as one-off, with no review after acquisitions or new product lines.
• Procedures focused on UK tax only, ignoring the foreign-tax limb of the offence.
• Associated persons (agents, intermediaries) outside the policy scope, despite being the most common facilitation route.
• Training generic, with no sector-specific scenarios.
• Whistleblowing channel absent or distrusted.

What Policy Pros Delivers

Our Anti-Tax Evasion Policy package includes the main policy aligned to the six HMRC principles, a tax-evasion risk assessment, a due-diligence procedure for associated persons, a training programme, a whistleblowing route, and integration with the AML, anti-bribery and modern slavery policies.