On 17 April 2016, UK HMRC published a consultation on draft legislation and guidance for the corporate offence of failure to prevent the criminal facilitation of tax evasion. The new offence is aimed at overcoming the difficulties in attributing criminal liability to corporations for the criminal acts of those who act on their behalf. The offence includes three main stages: Stage one: criminal tax evasion by a taxpayer (either a legal or natural person) under the existing criminal law (for example an offence of cheating the public revenue, or fraudulently evading the liability to pay VAT); Stage two: criminal facilitation...