Tax Strategy

University of Bristol Tax Strategy 2024 (PDF, 94kB)‌

Criminal Finances Act 2017

The Criminal Finances Act (CFA) 2017 comes into force on 30 September 2017.

One part of the Act introduces a new ‘corporate criminal offence of failure to prevent the facilitation of tax evasion by another party’.

There are two corporate offences:

The UK offence

This requires three conditions to be met

1. The criminal tax evasion by a taxpayer (either an individual or a legal entity) under existing law
2. The criminal facilitation of the tax evasion by an ‘associated person’ of the relevant body who is acting in that capacity
3. The University or its subsidiaries failed to prevent its representative from committing the criminal facilitation act. 

The Overseas offence

This requires three conditions to be met:

1. The criminal tax evasion by a taxpayer (either an individual or a legal entity) under existing law
2. The criminal facilitation of the tax evasion by an ‘associated person’ of the relevant body who is acting in that capacity
   • Stage A – Would this be a crime if carried out entirely in the UK?
   • Stage B – Does the overseas jurisdiction have the equivalent laws at Stage 1 and 2
3. The University or its subsidiaries failed to prevent its representative from committing the criminal facilitation act.

The University and its subsidiary companies are committed to ensuring that its employees, agents and other associated persons acting on the University’s behalf are not facilitating tax evasion by another party.

The University regularly reviews its risks and associated processes and procedures to ensure that all steps are taken to prevent facilitation of tax evasion.

The University maintains a register of possible risks of the facilitation of tax evasion by its staff and associates, as well as listing controls to mitigate those risks, and any actions required to improve those controls.  This register is regularly reviewed and updated (at least annually) as and when required in relation to the nature of the specific risks.

The University reviews its policies and guidance in relation to the Criminal Finance Act on an annual basis alongside similar policies.