As we move through the phases of lockdown, businesses are reopening across the country. Many are returning to a different way of working. For business leaders it's essential to ensure that your compliance policies and procedures still fit. At the top of the enforcement agenda right now is tax evasion.

In February HMRC communicated a strong commitment to pursue businesses for failure to prevent the facilitation of tax evasion. This should be an area of particular focus for the risk sectors singled out for attention by HMRC: financial services, oil and gas, construction, labour provision and software development. It's notable that pre-COVID-19 an HMRC commissioned poll showed that even in normal times the majority of businesses surveyed were not ready for this new offence.

We recently delivered a webinar discussing the rise of corporate offences, the six adequate or reasonable prevention principles which provide a defence to these offences, and the practical steps businesses can take to comply. The webinar is available to view here.

In the event of a compliance failure, the authorities will assess the extent to which an organisation has introduced policies and procedures in line with the six principles. A simple first step is to ensure that your organisation has performed a risk assessment across the full scope of its operations to understand the specific risks which arise for your business. Once those risks have been identified and understood, reasonable prevention policies and procedures can be implemented to manage those risks.

For those reopening for business now, a risk assessment is a great opportunity to start off on the right foot.

If you have any questions arising out of this article, or the webinar, please do not hesitate to get in touch with us.