Doing business with UK? Check your procedures to be compliant with the new legislation

08 November 2017

Attention UAE businesses that has UK clients/suppliers/branches or has agents doing business in the UK on its behalf: recently enforced UK legislation, the Corporate Criminal Offence of Failure to Prevent the Facilitation of Tax Evasion, which has come into effect starting from September 2017, impacts any organisation, anywhere in the world, that has UK clients/suppliers/branches or has agents doing business in the UK on its behalf. It is of particular relevance to Financial Services businesses and Trust Companies and any corporate service providers based outside the UK but who have UK clients.

Our team, led by Martin Callaghan, Senior Manager from BDO UK is specialising in helping companies to be compliant with the new legislation. Martin is expert in assisting financial institutions, including offshore trustees, in light of the ongoing focus on tax transparency; tax health checks and reviews of offshore accounts and structures to assist clients in ensuring that their affairs are compliant with UK taxation obligations. His role is to work with financial institutions and their clients in understanding the impact of global tax transparency and automatic information exchange (Common Reporting Standard/UK FATCA). 

BDO has developed a methodology which has helped to complete many successful projects up to date. 

For all our clients, the key to the Risk Assessment is the CCO Risk Register that considers each identified risk in detail.  Specifically, the Risk Assessment determines likelihood and materiality of the risk together with the existing controls for all areas of the business where there may be “associated persons” who could be facilitating tax evasion.

For some of our clients – depending on extent and complexity of risks – we support this with a Tax Evasion CCO Risk Assessment (TECRA) scoring methodology that aligns to the risks and controls as set out in HMRC guidance

Importantly, the risk and controls factors that we use in our methodology have been defined by HMRC in their guidance (originally articulated in the Bribery Act guidance) that organisations may wish to consider when responding to the CCO legislation and undertaking a risk assessment exercise.

For more details, updates and meeting/training invitation, please contact the Business Development team,