The Criminal Finances Bill has now received Royal Assent and most of its provisions are expected to come into force in the autumn. Part 3, ss 44-52, of the Criminal Finances Act 2017 creates two new tax criminal offences:

• a failure to prevent facilitation of UK tax evasion offences (s 45); and
• a failure to prevent facilitation of foreign tax evasion offences (s 46).

Both are corporate offences and can only be committed by ‘relevant bodies’, ie, companies and partnerships. Furthermore, the offences can only be committed in circumstances where a person acting for or on behalf of that body (an ‘associated person’) criminally facilitates a tax evasion offence committed by another person.

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