1. Purpose
This policy sets out Murzo Group's approach to preventing the criminal facilitation of UK or foreign tax evasion by any person acting for or on behalf of Murzo Group.
The purpose is to make clear that Murzo Group must not assist, encourage, conceal, enable, or turn a blind eye to tax evasion by customers, suppliers, workers, contractors, agents, distributors, property counterparties, overseas partners, or any other person.
2. Scope
This policy applies to all Murzo Group activities, including imports, exports, customs, VAT, payroll, property, high-value goods, cultural objects, fashion, food, farming, online sales, overseas work, local agents, commission payments, supplier payments, rebates, and professional advice.
3. Policy Position
Murzo Group prohibits tax evasion and the facilitation of tax evasion. This applies whether the tax at risk is UK tax, foreign tax, VAT, customs duty, excise, payroll tax, social security, withholding tax, corporation tax, income tax, property tax, or another tax or duty.
Procedures must be proportionate to the risk. Murzo Group should focus on clear approval, accurate information, transparent payments, legitimate advice, and escalation of suspicious requests.
4. Associated Persons
A person may create risk for Murzo Group if they perform services for or on behalf of Murzo Group. This can include workers, contractors, consultants, advisers, agents, distributors, introducers, brokers, local partners, customs representatives, fiscal representatives, and professional service providers.
Associated persons must not use Murzo Group activity to help anyone evade tax.
5. Red Flags
- Requests to understate value, split invoices, change product descriptions, or alter origin, VAT, or customs information
- Requests for cash, offshore payment, unrelated payees, overpayments, refunds to third parties, or unexplained commission routes
- Pressure to avoid invoices, avoid VAT, hide beneficial ownership, hide property ownership, or misstate business purpose
- Advice that appears designed to conceal income, profits, payroll, customs duty, property gains, or taxable supplies
- Use of agents, distributors, or contractors with unclear services, inflated fees, or no transparent commercial purpose
- Requests to treat workers as contractors, consultants, volunteers, or overseas service providers where the facts do not support it
6. Controls
- Use accurate invoices, customs values, VAT treatment, payment descriptions, payroll classifications, and contractual terms
- Check high-risk tax positions with suitable internal or external advice before commitment
- Do not accept tax, customs, payroll, or offshore arrangements that rely on concealment or false documents
- Apply proportionate due diligence to high-risk agents, advisers, property counterparties, and international structures
- Escalate tax evasion concerns before payment, shipment, contract signature, invoice issue, or authority submission where practical
7. Overseas Activity
Foreign tax evasion risk must be considered where Murzo Group operates, sells, buys, stores goods, pays agents, posts workers, leases property, or uses local representatives outside the UK.
Local custom, commercial pressure, or local partner advice is not a defence to dishonest or concealed tax treatment.
8. Reporting and Response
Concerns must be raised promptly with an authorised Murzo Group manager or adviser. Murzo Group may stop the transaction, refuse a payment, replace an adviser, terminate a relationship, correct information, seek legal advice, notify authorities, or take disciplinary action.
Evidence should be limited to what is needed to understand the concern, obtain advice, respond to authorities, protect Murzo Group, and make a lawful decision.
9. Review
This policy will be reviewed when Murzo Group enters a new market, changes tax or customs structure, appoints overseas agents, starts local employment, acquires property, or identifies a new tax evasion facilitation risk.
