Anti-Tax Evasion Policy

This policy sets out Wiltshire Council's policy to tax evasion. It has the full support of both the Council's senior management in the form of the Chief Officers and elected members through Audit & Governance Committee.  As part of the Council's Constitution the Council's Audit & Governance Committee has responsibility for Anti-Fraud and Corruption Policy and this Anti-Tax Evasion Policy supports the specific area of tax evasion alongside the existing zero tolerance position on fraud, bribery and corruption.

Part 3 of the Criminal Finances Act 2017 created a new corporate criminal offence where a corporate entity fails to prevent the facilitation of tax evasion by its staff, agents and contractual associates.

The purpose of the Anti-Tax Evasion policy is to support the specific area of tax evasion alongside the existing zero tolerance position on fraud and corruption, to provide guidance to staff and others on action to prevent or report on tax evasion or the perception of tax evasion and to emphasise the need to be aware and to continue the Council's good record. It has been reviewed and updated in 2024 to reflect changes required to ensure all aspects of anti-tax evasion risks are captured.

Governance and internal control procedures are already in place to meet the statutory requirements; and there is no suggestion that the Council tolerates tax evasion, or that staff engage in such behaviour. However, adopting an express corporate policy will help the Council defend any allegation that it has facilitated tax evasion.

The Council is, however, determined to protect itself against all areas of fraud including tax evasion both from within and from external sources. The Council already has in place a Constitution, which includes Codes of Conduct and Protocols setting out expected behaviours of both members and employees. It also includes Financial Regulations which provide clarity about accountabilities of individuals, Members, Corporate Leadership Team etc. The HR content on the Council's Intranet site includes detailed standards of conduct expected of staff.

The Anti-Tax Evasion Policy brings together the key elements from both the Council's and government documents and provides a link to where further information may be found. As part of its aim to ensure Value For Money (VFM) and Efficiency, the council is committed to an effective Anti-Tax Evasion policy designed to:

• ensure prevention;
• facilitate detection; and
• identify a clear pathway for investigation and remedial action.