Background
The Criminal Finances Act 2017 received Royal Assent on 27 April 2017 and came into force on 30 September 2017. Part 3 of the Act created two corporate criminal offences for failing to prevent the criminal facilitation of UK and foreign tax evasion. A company can be held criminally liable for the actions of its employees, agents and other "associated persons" who facilitate tax evasion in the course of acting for the company — even where senior management was unaware.
The only defence is to show that the company had reasonable prevention procedures in place, or that it was not reasonable in the circumstances to expect such procedures. HMRC's guidance frames those procedures around six principles: risk assessment, proportionality, top-level commitment, due diligence, communication (including training), and monitoring and review.
Our commitment
Microsystems International (UK) Limited has zero tolerance for tax evasion and for the criminal facilitation of tax evasion, whether under UK law or the law of any other jurisdiction. We are committed to acting professionally, fairly and with integrity in all our dealings, and we apply this policy to every employee, director, contractor employed through our umbrella, supplier, agency, end-client and other associated person.
What we do not do
In particular, we do not, and will not knowingly assist any person to:
- Make false statements, whether written or verbal, in connection with income tax or any other personal taxes;
- Produce or rely on false documents in relation to income tax;
- Fail to disclose income that should be declared to HMRC;
- Fail to operate PAYE and National Insurance correctly;
- Fail to register for VAT where required, or fail to account for VAT;
- Operate or promote any disguised remuneration arrangement, loan scheme, offshore intermediary or other arrangement that has the effect of disguising employment income.
Reasonable prevention procedures
Our prevention procedures include written terms with every contractor and supplier prohibiting the facilitation of tax evasion, risk-based due diligence on agencies and end-clients in our supply chain, training for staff in customer-facing and payroll roles, clear internal escalation routes, and periodic review by senior management. From 6 April 2026, additional supply-chain due diligence is required to address the joint and several liability for unpaid PAYE and Class 1 NICs introduced by Chapter 11 of ITEPA 2003.
Reporting concerns
Anyone — employee, contractor, agency, client or supplier — who suspects that an associated person of Microsystems International has facilitated tax evasion, or is about to, should report it immediately. Concerns can be raised through line management or through the channels set out in our Whistleblowing Policy. Reports made in good faith are protected from retaliation.