I've had a potential new company client contact me, asking whether I can provide a service of carrying out a risk assessment within their company in order to ensure that they have relevant procedures in place in respect of the new 'Corporate offence of failure to prevent the criminal facilitation of tax evasion'. Although I've thought about the position from my firm's perspective (under which we would follow specific guidance from our accounting and tax regulatory bodies, in the same way that we always would), I must say that I hadn't really thought about whether we should be looking to advise company clients as to whether they would need to put relevant procedures in place themselves (for instance becuase their employees or subcontract staff would be deemed to be associated persons and therefore could be caught in the net?)
Has anyone else given any thought to this? Or are already giving clients advice on what they should be doing?
Thanks!
