HMRC has published guidance for firms on self-reporting a breach of the CFA provisions on failure to prevent facilitation of tax evasion. HMRC stresses that:
- reporting must be done only by an authorised representative of the firm
- reporting is not a requirement, and is not a defence
- however, it may be viewed as part of “reasonable procedures”
- a report to HMRC under this mechanism is not a SAR, which should be made separately if appropriate