Anti-Facilitation of Tax Evasion Policy Template for Singapore

An Anti-Facilitation of Tax Evasion Policy helps organizations prevent their employees and associates from helping others evade taxes. It outlines clear rules and procedures that companies in Singapore must follow to stop staff from knowingly or unknowingly assisting clients, vendors, or partners in tax fraud schemes.

Following Singapore's strict tax compliance framework, this policy sets up internal controls, reporting channels, and risk assessment processes. It protects companies from criminal liability under local tax laws while promoting ethical business practices. Staff training, due diligence procedures, and regular policy reviews form key parts of this defensive strategy against tax evasion risks.

Consider implementing an Anti-Facilitation of Tax Evasion Policy when your organization works with multiple business partners, handles complex financial transactions, or operates across borders. This policy becomes essential for Singapore-based companies dealing with international clients, managing substantial cash flows, or offering financial advisory services.

The policy proves particularly valuable during mergers and acquisitions, when onboarding new high-risk clients, or expanding into new markets. It helps protect your organization from criminal liability under Singapore's tax laws and demonstrates commitment to compliance when dealing with regulatory authorities like IRAS. Many companies implement it alongside their anti-money laundering and corporate governance frameworks.

• Basic Policy: Outlines fundamental controls and procedures for preventing tax evasion facilitation, suitable for small-to-medium enterprises in Singapore
• Enhanced Due Diligence Policy: Includes additional screening measures and risk assessments for organizations handling high-risk transactions or clients
• Industry-Specific Policy: Tailored for sectors like financial services or real estate with unique tax evasion risks
• Group-Wide Policy: Comprehensive version for multinational corporations, covering cross-border transactions and multiple jurisdictions
• Simplified Policy: Streamlined version for small businesses with straightforward operations and limited international exposure

• Board of Directors: Responsible for approving and overseeing the Anti-Facilitation of Tax Evasion Policy, ensuring corporate-wide compliance
• Compliance Officers: Draft, implement, and monitor the policy, conducting regular risk assessments and updates
• Finance Teams: Apply the policy in daily operations, flagging suspicious transactions and maintaining documentation
• HR Departments: Train staff on policy requirements and manage reporting channels for potential violations
• External Advisors: Legal and tax consultants who help customize the policy to meet Singapore's regulatory requirements
• Employees: Must understand and follow the policy guidelines in all business dealings and report concerns

• Risk Assessment: Review your business operations, international exposure, and existing tax compliance processes
• Industry Analysis: Identify sector-specific tax evasion risks and compliance requirements in Singapore
• Stakeholder Input: Gather feedback from finance, legal, and compliance teams on practical implementation needs
• Process Mapping: Document current financial controls, reporting procedures, and risk management systems
• Training Needs: Assess staff knowledge gaps and plan educational requirements
• Technology Review: Evaluate existing systems for monitoring and reporting capabilities
• Documentation Plan: Outline record-keeping requirements and compliance tracking methods

• Policy Statement: Clear commitment to preventing tax evasion facilitation and compliance with Singapore tax laws
• Scope Definition: Detailed coverage of activities, employees, and third parties bound by the policy
• Risk Assessment Framework: Procedures for identifying and evaluating tax evasion risks
• Due Diligence Procedures: Steps for screening business partners and transactions
• Reporting Mechanisms: Clear channels for reporting suspicious activities and protection for whistleblowers
• Training Requirements: Mandatory staff education and awareness programs
• Enforcement Measures: Consequences for non-compliance and disciplinary procedures
• Review Process: Schedule for regular policy updates and effectiveness assessments

An Anti-Facilitation of Tax Evasion Policy is often confused with a Compliance and Ethics Policy, but they serve distinct purposes in Singapore's regulatory landscape. While both address organizational conduct, their scope and focus differ significantly.

• Specific vs. Broad Focus: Tax evasion policies specifically target preventing assistance in tax fraud, while compliance and ethics policies cover general business conduct and moral standards
• Legal Requirements: Tax evasion policies directly respond to tax laws and IRAS requirements, whereas compliance and ethics policies address multiple regulatory frameworks
• Risk Management: Tax evasion policies concentrate on financial transaction risks and tax reporting, while compliance and ethics policies cover broader operational risks
• Implementation: Tax evasion policies require specific financial controls and monitoring systems, whereas compliance and ethics policies focus more on general behavioral guidelines and corporate values