M22/2017 TACKLING TAX EVASION: GOVERNMENT GUIDANCE FOR THE CORPORATE OFFENCES OF FAILURE TO PREVENT THE CRIMINAL FACILITATION OF TAX EVASION – GOVERNMENT GUIDANCE
[HMRC, September 2017]
1.1 Aim of the legislation
The Government believes that relevant bodies should be criminally liable where they fail to prevent those who act for, or on their behalf from criminally facilitating tax evasion.
The new offences will be committed where a relevant body fails to prevent an associated person criminally facilitating the evasion of a tax, and this will be the case whether the tax evaded is owed in the UK or in a foreign country.