ACCOTAX – Accountants & Tax Consultants & all associated website with the logo of ACCOTAX – Accountants & Tax Consultants is a trading name of Accotax Limited. The company is registered in England & Wales under the registration number 07057125. The Company’s registered office address is 12 London Road, Morden, SM4 5BQ. The company is also registered for VAT and the VAT registration number is 993492370. This page contains a few important disclaimers and notices, please read them carefully.
We are fully licensed by ICAEW & AAT to carry out Accounting & Taxation related services. The insurance is provided by Hiscox. We have employers’ liability Insurance of £5 Million, public liability insurance of £1 million and professional indemnity insurance of half a million through Hiscox Insurance. Insurer Hiscox Insurance Company Limited: Registered address 1 Great St Helens, London, EC3A 6HX United Kingdom, Company registration Registered in England number 00070234 Status Hiscox Insurance Company Ltd is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority.
Business E-mail Disclaimer.
This email and any attachments to it may be confidential and are intended solely for the use of the individual to whom it is addressed. Any views or opinions expressed are solely those of the author and do not necessarily represent those of Accotax – Accountants & Tax Consultants. If you are not the intended recipient of this email, you must neither take any action based upon its contents, nor copy or show it to anyone. Please contact the sender if you believe you have received this email in error.
Copyright Notice & TRADEMARKS
The name “ACCOTAX – Accountants & Tax Consultants” and the logo are the trademarks of Accotax – Accountants & Tax Consultants. They are registered in the UK under the trademark number -UK00002579731. It can be viewed on the intellectual property website. In addition, This website and its content are copyright of ACCOTAX – Accountants & Tax Consultants- © Accotax Limited 2016. All rights reserved. Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:
• you may print or download to a local hard disk extracts for your personal and non-commercial use only
• you may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material
You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.
Accotax limited is registered with the Information Commissioner’s Office under registration reference ZA197888 . Sections 11 and 12 of the Data Protection Act 1998 place express obligations on you as a data Controller where we as a data processor undertake the processing of personal data on your behalf. We therefore confirm that we will at all times comply with the requirements of the Data Protection Act 1998 when processing data on your behalf. In particular, we confirm that we have adequate security measures in place and that we will comply with any obligations equivalent to those placed on you as a data controller.
The information contained in this website is for general information purposes only. The information is provided by ACCOTAX – Accountants & Tax Consultants- and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.
In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arise out of, or in connection with, the use of this website.
Through this website you are able to link to other websites which are not under the control of ACCOTAX – Accountants & Tax Consultants-. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them. Every effort is made to keep the website up and running smoothly. However, ACCOTAX – Accountants & Tax Consultants- takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.
This page contains the information gathering and use policies adopted by ACCOTAX – Accountants & Tax Consultants in connection with this web site. These policies are subject to periodic review and any changes will be included within this section of the site.
ACCOTAX – Accountants & Tax Consultants are not responsible for the privacy policies of third party sites to which links are provided. You should check the privacy policies on these sites before providing any personal information.
Collection of Information
IP addresses of visitors are logged for administration purposes. The IP address indicates the location of your computer on the Internet. This information may be aggregated to provide statistical information about the users of our site. No individual user will be identifiable from such information, which is used to ensure the ACCOTAX – Accountants & Tax Consultants web site reflects the needs of users. IP addresses are not used to track your session and are not linked to anything personally identifiable. ACCOTAX – Accountants & Tax Consultants does not require registration for access to the site.
It will normally be clear when personal information is being collected.
Personal information is generally collected for the following purposes:
• So we can deliver requested materials or information
• If you book to attend an event
• If you submit an online form.
• If you apply to work for ACCOTAX – Accountants & Tax Consultants
• If you register for access to a secure area of our site used to exchange information between us
The information required is necessary to enable ACCOTAX – Accountants & Tax Consultants to deal with your enquiry, but additional information may be requested to help us to provide the most appropriate response. If such additional information is requested, it is highlighted and its provision is voluntary.
Sensitive information is not sought through the web site except where legally required as part of the recruitment process. Sensitive information includes data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. Where you do provide sensitive information this will be accepted as explicit consent to ACCOTAX – Accountants & Tax Consultants to use that information in connection with the purpose for which it has been provided.
Use of Information
The information is used only for the specific purpose for which it was provided except where you explicitly select to receive other information from ACCOTAX – Accountants & Tax Consultants. When requesting material or asking someone to contact you, you may have the option to request other information that may be of interest. You can opt out of receiving information from ACCOTAX – Accountants & Tax Consultants or request that your personal details are deleted from our systems at any time by e-mailing us at firstname.lastname@example.org.
Accuracy of Information
ACCOTAX – Accountants & Tax Consultants assumes responsibility for keeping an accurate record of personal data once you have submitted the information, but not for confirming the on-going accuracy of your personal information. If you advise ACCOTAX – Accountants & Tax Consultants that your personal data is no longer accurate, it will be amended (where practical).
Provision of Information to third Party
Information is normally only provided to a third party if it is required to deal with your enquiry, but there may be other circumstances where ACCOTAX – Accountants & Tax Consultants is required to provide information as a result of legal process. ACCOTAX – Accountants & Tax Consultants does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes. But we may time to time introduce products or services to our client who we think are of your benefits.
Retention of Information
The information is kept for as long as is necessary to fulfil your request or deal with your job application. Where you have consented to additional information being provided by ACCOTAX – Accountants & Tax Consultants your details will be retained for a reasonable period of time.
Security of Information
The data controller collecting the information described in this statement is ACCOTAX – Accountants & Tax Consultants. Generally accepted standards of technology and operational security have been implemented to protect personal information from loss, misuse, alteration or destruction. All ACCOTAX – Accountants & Tax Consultants personnel are required to keep personal information confidential and only authorised persons have access to such information.
Other Terms and conditions for website usage.
• The content of the pages of this website is for your general information and use only. It is subject to change without notice.
• Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
• Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
• This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
• All trade marks reproduced in this website which are not the property of, or licensed to, the operator are acknowledged on the website.
• Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
• From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
• Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.
Our Standard Terms Of Engagement.
We are pleased to accept the appointment as your accountants and tax consultants. The purpose of this letter is to set out the basis on which we are going to act and our respective responsibilities. If you are signing up for one specific service, only the relevant services & relevant service’s terms will be applicable to you.
1. Accounting – Year End Accounts
1.1 You have instructed us to prepare your financial statements each year from the record provided by you.
1.2 You have agreed that you or your staff will:
(a) Keep the records of receipts and payments;
(b) Keep the records of sales invoices and expense invoices;
(c) Keep all bank and credit card;
(d) Any other relevant information.
(e) Provide us the accurate information to prepare the accounts & Tax Returns
(f) Provide us information on time
2. Corporation tax
2.1 This engagement will commence with the next company’s tax return we work on.
2.2 We will prepare, from the accounts and other information and explanations provided by you, the company’s corporation tax return and computations, together with all supporting schedules and, where necessary, amended returns.
2.3 We will send you the tax return and supporting schedules for you to approve and sign. We will then submit it, with the accounts and computations, to H M Revenue & Customs.
2.4 We will advise you of the amounts of corporation tax to be paid and the dates by which the company should make the payments. Where appropriate, we will initiate repayment claims when tax has been overpaid.
2.5 We will deal with all communications relating to the company’s tax return addressed to us by H M Revenue & Customs or passed to us by the company, and subject to the nature of the communication, may need to be the subject of a separate assignment in which case we will seek further instructions from you. However, if H M Revenue & Customs choose your return for enquiry this work will need to be the subject of a separate assignment in which case we will seek further instructions from you.
2.6 We will prepare the tax provisions and disclosures to be included in the company’s statutory accounts.
The Fee is charged as per the accounting year of the company, which is based on the turnover and work involved. For the standalone services the period from the company accounts will be as per the period of company’s house.
3. Payroll and year end returns
3.1 We will maintain your payroll records, supply you with completed weekly/monthly payslips for you ( on request) to pass to employees, supply you with details of the PAYE and National Insurance Contributions for you to send to the Collector of Taxes with a cheque which you will draw, complete your year end return form P35 with forms P14 and P60 and supply you with the completed form P35 for signature and submission by you to H M Revenue & Customs with forms P14 and the forms P60 that you will pass to each employee.
3.2 In order to do this we need to comply with the Employer’s Guide to PAYE: We will consider with you the detailed information that is required and the form in which it is to be provided.
3.3 Setting up pension and pension related services are charged separately and the fee is not included in the payroll unless agreed in advance in writing.
3.4 If you have requested us to deal with pension, we will provide you a separate quotation, where the rest of the terms will remain same as written in this agreement. Additional shareholders or employees on the payroll will incur additional charges. Please ask us for a quote if this applies in your case.
The payroll period runs from 1st April to 31st March every year, For all inclusive packages the fee is charged as per the accounting year of the company, whereas for the standalone or one off service package/service the fee is charged as per the payroll period.
4. Value Added Tax (VAT), EC Sales List, VAT Moss
4.1 If at the time of this letter you are not VAT registered and registration becomes necessary, we will endeavour to ensure that you register in time provided that:
(a) you notify us in writing within 10 days of the end of each month of the total value of supplies you have made in that month; and
(b) You notify us immediately in writing if the value of taxable supplies that you will make in the next 30 days is likely to exceed the annual registration limit then in force.
(c) Where you business is registered for the VAT during the year, you will be charged according to the fee schedule. It is your responsibility to confirm us if you are not sure about the charges.
The VAT period runs as per the dates given by HMRC ( Usually every three months), For all inclusive packages the fee is charged as per the accounting year of the company , whereas for the standalone or one off service package/service the fee is charged for each return we prepare for VAT, EC sales list, VAT Moss.
5. Company Secretarial
5.1 You have agreed to complete all the returns required by law, for example, the Confirmation Statement (previously annual return) and the notification of changes in directors. We shall, of course, be pleased to advise you on these and any other company secretarial matters if requested at a fixed cost. If we are filing confirmation statement, the fee will be charged on a yearly basis. It is your responsibility to inform us about any changes that occurred during the year so that we can update the company’s house.
Registered Office Address:
If you are using registered office address facility, it must not be used for any criminal activity. You are not authorised to use our office address without our written permission. Failure to do so will lead to a legal action. You are not authorised to use our office address to obtain any loans, Cars, or any sort of items. We are only responsible to scan & email to you the correspondence from the company’s house & HMRC. All the registered office address facility must be paid in advance, failure to do so will lead to a notification to the company’s house where your company will be frozen along with its bank accounts. It is your responsibly to take any money out from the business accounts where you have authorised us to strike off the company.
The fee for the registered office is charged on an yearly basis in advance, It will be for the period of 12 months from the date you take such services.
6. Other Services
6.1 However, there are many other areas where we can be of assistance and we shall be pleased to discuss any matters with you. These other services include:
(a) business growth strategies, management accounting, including such matters as cash flow statements, costing systems, etc., and advice on management, Bookkeeping, Pensions etc
(b) Reduction of tax bills, Fee Protection Insurance, Tax Investigations. Tax Investigations are not part of the services unless written & agreed in advance.
For any other services, we may not be able to issue a separate letter of engagement to reduce the admin work. Therefore the same letter of engagement terms will be applicable on you for all the future services that we agree in writing or by the email. You will be charged as per the fee schedule, or fee agreed in advance for the services that you have selected/opted. For any other services, you will be sent a separate invoice. Please confirm in writing if you are unsure.
7. Our Fee & Setting up a Direct Debit.
7.1 The subject of accounting fees is obviously of interest both to us and to you. You as a client want to feel you are getting your money’s worth for the fee you pay, and we must have fees that are adequate to enable us to give a good service. All the Customers must setup a direct debit in order to obtain our service, where direct debit is not set, we may not be able to provide you the services.
In much of the work we do, we are reasonably able to predict how much time it should take, and are willing to make a firm estimate of this fee in advance. Often it is impossible to predict all the problems we are likely to encounter on the job. Hence, if within doing work to the value if 30% of the quoted fee finds that our estimate was materially wrong, we will discuss this with you prior to incurring further fees.
7.2 Our fees are based on the time necessarily spent on your affairs by the partners and staff involved. Some clients are billed at agreed intervals, and our settlement terms are as follows:
a) Our fee/invoice must be settled within 10 days of the invoice date or as mentioned on the invoice, or before the accounts due date (where applicable). If the accounts due date is before the invoice due date, the accounts due date will be considered as invoice due date.. If the 10 day period is exceeded they are deemed overdue. If you are paying on a monthly basis, you will be invoiced on the 1st of each month and you will be paying one month in advance.
b) If fees are not settled within the due date from the fee note date, on the 11th day ( or soon after the due date) the service charges will be charged at a minimum of 3% per month from the date they became overdue, or as it is written on the invoice whichever is higher. Whilst any amounts are outstanding, accotax reserves the right, at its sole discretion, to suspend the provision of all services, including services provided that are covered by separate terms of engagement. Where services are suspended all obligations attached to accotax under all terms of engagement are also suspended and no liability is accepted for consequential losses, late filing penalties, interest or other charges.
c) All fee notes/invoice shall be deemed conclusive of the sums due and payable to you under them and may not be challenged other than in writing within 10 days of your receiving the disputed fee note concerned.
d) Where you are unable to pay the invoice on the due date, we have authority/right to refer your case to debt collectors or legal team; you will be responsible to pay service charges, administration fee, debt collector’s fee and any other legal fee that may incur. In the event of non-payment of our fees for services rendered, we may exercise a particular right of lien over the books and records in our possession and withhold the documents until such time as payment of our fees is received in full.
e) Our fee is calculated as per the as per the accounting year of the company (for limited companies). Say your company is setup in January and your year end is in December, and we have agreed a fee of £500 plus VAT. The fee will cover the period from January to December.
If you join us during the year, the fee for the previous months will be charged. E.g, if you are a contractor/business and your accounting year runs from January to December, Say, you joined us in the beginning of July and we have agreed a fee of £100 per month, it means your yearly fee will be £1200 a year ( from January to December)..Where either you will pay us six months in advance from January to June, or we will charge you £200 from July to December to cover the previous 6 months fee. And from the next January you will start paying 100 every month.
When you join during the year, or after the year, we have to do all the previous accounts & tax returns hence the above is applicable. If you are a contractor and lose your contract during the year, our fee will still be charged as we have to do the accounts for the whole year. Where you decide not to pay because of lack of funds, we may freeze the services and invoice you on pay as you go basis as per our fee schedule; therefore it is your responsibility to confirm with us about pay as you go fee as it may be more than the contractor’s fee agreed in advance.
f) For one off tasks, you will be requested to pay 50% in advance to start the work and 50% before filing/submission. We do have right to hold the submission where the fee is not paid in full and will take no responsibility for the late filing penalties.
g) Regarding our fee, the direct debit has to be setup on the following link within 7 days of signing this agreement. Where direct debit is not set up by the client in 7days, I authorise Accotax to arrange a direct debit in place using my bank detail anytime and has right to collect the outstanding payment from my business/personal bank account ,credit or debit card information accotax hold without notifying to me/client. This agreement gives accotax the authority to set up the direct debit with the go cardless/Directli or any other service provider that accotax use.
7.3 We enter into a trusting relationship. The director/business owner instructs us knowing their ability to meet our fees. If the Company/business is unable to pay our fees incurred from time to time for whatever reason, the directors/business owner personally accepts the liability for our charges. It is the responsibility of the director/business owner who is signing this agreement, to inform a new director (where the company is sold, transferred to some family members, etc.) about this clause that the new director/business owner will be personally liable for our fee. Moreover, Directors/business owner (existing, new) will be personally liable for any debt they owe to our firm in any case, even where the company/business is liquidated or has been struck off. We have full right to take legal action against the director/business personally, for the outstanding fee.
7.4 Should you leave during the year, you will be charged £75.00 plus VAT per hour for all the services carried out during our engagement. This is usually applicable to those who do not pay on a monthly basis.
7.5 This Letter of engagement will be renewed automatically every year unless it is requested by the client. Should you want to leave Accotax for some reason, kindly inform us 28 days before leaving in writing; The entire outstanding invoice must be clear before you leave.
7.6) Our fee is usually based on the turnover & work involved. We /our system will provide you a quotation based on your requirement and the information that you have supplied to us. If your turnover goes up during the year, or you do not provide us information in the same format as agreed at the beginning, it means you will fall into a different band. Therefore, we will send you an invoice for the additional turnover & work involved. e.g, If you say your turnover is £10K a year, and you will provide us information on a software, it is implied we will quote you as per the information supplied. If the year end, your turnover is more than £50K or information is not supplied on a software, we do have right to charge you according to our fee schedule. Therefore, it is your responsibility to supply us the correct information at the beginning to get an exact quote, and to inform us during the year where your circumstances are changed.
If you need any additional services (besides what you are agreeing/signing) during the year, the same terms will automatically be applied to you and we may not ask you to sign a new agreement to save time.
8. Retention of and access to records
8.1 During the course of our work we will collect information from you and others acting on your behalf and will return any original documents to you following the preparation of your accounts.
8.2 All Original documents will be returned to you, or must be collected within 3 months of us completing your accounts. Original documents left at our premises after this time are archived at your cost £2 per box per week. Sending us copies or electronic versions is cheaper, safer and quicker. Faxes, emails, scan documents are all acceptable.
8.3 Whilst certain documents may legally belong to you, we intend to destroy correspondence and other papers that we store which are more than seven years old, other than documents which we consider to be of continuing significance. If you require retention of any document you must notify us of that fact in writing.
9. Quality control & Confidentiality
9.1 To ensure a rapid response and cost effective service to you, we, on occasions, employ sub-contractors, who may work from home because of child minding requirements, or disability issues. They are appropriately qualified and provide a valuable resource to the firm.
9.2 All our staff and sub-contractors are professional and appropriately qualified. They are under a confidentiality agreement.
9.3 As part of our ongoing commitment to provide a quality service, our files are periodically subject to an independent quality review. Our reviewers are highly experienced and professional people and are, of course, bound by the same requirements of confidentiality as our principals and staff.
10. Help us to give you the right service
10.1 If at any time you would like to discuss with us how our service to you could be improved, or if you are dissatisfied with the service you are receiving, please let us know, by calling us.
10.2 We undertake to look into any complaint carefully and promptly and to do all we can to explain the position to you. If you feel that we have given you a less than satisfactory service,we undertake to do everything reasonable to address your concerns.
11. Electronic communication
11.1 Internet communications are capable of data corruption and therefore we do not accept any responsibility for changes made to such communications after their despatch. It may therefore be inappropriate to rely on advice contained in an e-mail without obtaining written confirmation of it. We do not accept responsibility for any errors or problems that may arise through the use of internet communication and all risks connected with sending commercially sensitive information relating to your business are borne by you. If you do not agree to accept this risk, you should notify us in writing that e-mail is not an acceptable means of communication.
11.2 If correspondence is requested in paper format, the disbursement charge of £50 per year is payable to cover the handling and postage of the correspondence.
11.3 It is the responsibility of the recipient to carry out a virus check on any attachments received.
12. Contracts (Rights of Third Parties) Act 1999
12.1 Persons who are not party to this agreement shall have no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of this agreement. This clause does not affect any right or remedy of any person which exists or is available otherwise than pursuant to that Act.
13. Limitation of liability
13.1 We will provide our professional services with reasonable care and skill. However, we will not be held responsible for any losses arising from the supply by you or others of incorrect or incomplete information, or your or others’ failure to supply any appropriate information or your failure to act on our advice or respond promptly to communications from us or other relevant authorities.
14. Late filing penalties
14.1 There are a number of penalties for late filing of returns, etc. To ensure that we are able to meet these deadlines on your behalf, we must identify when information has to be submitted to our offices. We list below the most common requirements.
Item Due to Authorities Due to us
Accounts Up to 9 months from Year end (Tax) 12 weeks from period end
VAT Returns By end of month following relevant 10 Days after end of period
SA Tax Returns By 31st October (Paper filing only) by 30th June after Year end
PAYE Returns By 19th May By 1st May
Monthly Payroll By 5th of every month by 27-28th of same month.
We will not be held responsible for any penalties arising where the information is not with us by the due date. If you are in any doubt, you should contact us to check. Further, you are requested to reply to our queries by return of post (within 3 working days). This is essential where we are close to the deadline (within 30 days).
We need at least 28 working days to complete the accounts, 14 Days to complete the VAT returns, 4 days to do the payroll & 21 days to do the personal tax returns. Where you need any of them on urgent basis, we may charge an additional fee for the extra time and effort we put in.
14.2 We send reminders most of the times before anything is due, therefore you may be getting emails and phone calls to ensure you don’t miss any deadline. It your responsibility to allow us to provide us the requested information on time, we will not be responsible for any penalties especially where information is not provided on time from your end.
14.3 We get busy time to time; therefore it is your responsibility to allow us a minimum time to perform the tasks as given below, unless we have agreed something different in writing with you.
Personal Tax Return: at least 21 working days
Year End Accounts: at least 28 working days
Payroll & PAYE: 48 Hours
VAT Returns: at least 14 working days
We have right to charge you an extra fee, where the above timescale is not given (despite of several reminders) to complete the tasks. A minimum additional fee of £50 for personal tax return, VAT £30, Accounts from £100, Payroll from £15 will be applicable. However, be in no doubt that we will always do our utmost to ensure that you are not subjected to penalties.
14.4) Anti Money Laundering Legislation
All accountants must comply with onerous duties imposed by the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering Regulations 2007 (the Anti Money Laundering Legislation), which are intended to inhibit the activities of terrorists and other criminals by denying them access to technical expertise. If we fail to perform these duties, we risk imprisonment.
Before we accept your instructions, we may need to obtain ‘satisfactory evidence’ to confirm your identity. In certain circumstances, we may need to obtain evidence confirming the identities of third parties, the source of any funds or other property, the purpose of any instructions or any other matter. We may also need to obtain such evidence after we have begun to act on your instructions, we may do this by electronic means.
We assume that our clients are honest and law abiding. However, if at any time, there appear to be grounds to suspect (even if we do not actually suspect) that your instructions relate to ‘criminal property’, we are obliged to make a report to the Serious Organised Crime agency (SOCA), but we are prohibited from telling you that we have done so.
In some such circumstances, we must not act on your instructions without consent from SOCA. If SOCA does not refuse consent within seven working days we may continue to act. If SOCA issues a refusal within that time, we must not act for a further 31 days from the date of the refusal.
‘Criminal property’ is property in any legal form, whether money, real property, rights or any benefit derived from criminal activity. It does not matter who carried out the criminal activity or how removed the property is from the original crime. Even if you are honest in your dealings, if your property represents a benefit from someone else’s crime, we must still make a report.
Activity is considered ‘criminal’ if it is a crime under UK law, no matter how trivial, and whether carried out in the UK or abroad. For example, tax evasion is a criminal offence but an honest mistake is not.
15. Client monies
15.1 We choose not to hold client monies, but, We may, from time to time, hold money on your behalf. Such money will be held in trust in a client bank account, which is segregated from the firm’s funds. If there are grounds to suspect (even if we do not actually suspect) that any monies held in a client account is derived directly or indirectly from any criminal activity whatsoever, we may not release such monies until we receive permission to do so from SOCA.