Effective Date: 01 Oct 2018 | Last Review Date: 01 April 2025 | Owner: Management | Version: 1.1
Neutrino Group and its entities are committed to complying with all applicable tax laws and will not facilitate, assist, or enable tax evasion by any client, partner, or third party. This policy reflects our obligations under the UAE tax framework only.
1. Purpose
This policy ensures that all the entities of Neutrino Group, its employees, and associated persons do not directly or indirectly facilitate tax evasion by any third party, including clients, suppliers, or business partners.
2. Scope
This policy applies to all employees, contractors, directors, and any third party performing services on behalf of Neutrino Group and its entities.
3. What Is Tax Evasion Facilitation?
Facilitation of tax evasion occurs when a person deliberately and dishonestly assists another person in evading taxes they legally owe. This includes:
- Helping structure transactions to deliberately hide income or assets from tax authorities
- Providing false or misleading documentation to enable tax evasion
- Knowingly enabling a client or partner to misrepresent their tax position
- Tax avoidance (legal tax planning) is distinct from tax evasion and is not covered by this policy.
4. Our Commitment
Neutrino Group and its entities commits to:
- Never facilitate, aid, or encourage tax evasion by any person or
- Conducting reasonable due diligence on significant transactions and new business relationships.
- Maintaining accurate and transparent financial
- Ensuring all invoices, contracts, and payments are properly documented and reflect true commercial transactions.
5. Red Flags
Employees should be alert to and report the following warning signs:
- Requests for payments to be made to undisclosed third parties or in
- Unusual or complex payment structures with no clear business
- Requests for invoices to describe services
- A client or partner expressing interest in reducing tax liabilities through questionable means.
6. Reporting
Any employee or contractor who suspects or becomes aware of an activity that may constitute facilitation of tax evasion must report this immediately to senior management. All reports will be treated seriously and investigated promptly.
7. Training & Awareness
Neutrino Group and its entities will ensure relevant personnel are made aware of this policy and understand their obligations. This will be incorporated into onboarding and periodic compliance reviews.
8. Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action and could expose Neutrino Group and its entities along with the individual concerned to significant legal and financial penalties..