We're going to discuss a provision in the 2014 Companies Act that didn't attract a lot of attention when it first came out but is now finding its way firmly onto the radar of company directors and senior management so really maybe you'd start by telling us what's this about okay Peter where this is brand new and the directions compliance statement or dcs was introduced in the first of jun 2015 and impacts a lot of companies for the first time directors have to confirm in the director's report that is on three things concerning complete law and the taxes acts those two things are one have a compliance policy in place to have adequate controls to support that policy and three to have that those controls tested during the year okay so what's different between this and what happened what was in in place before okay well directors always have these responsibilities but for the first time there's no requirement to evidence them so it really is raising the bar and putting more obligations and i'd say more pressure and directors to ensure that these things are done correctly okay looking at the policy what should be in that policy it's actually good opportunity for directors and management to have discussions around this and to formalize what they see is their overall objectives as were in relation to tax compliance and compiler compliance and and won't see things such as the context the scope work legislation is applicable to them which may vary again from company by company and also things like they can set out who's responsible for it and importantly they can outline what are the different measures they hope to put in place okay and andy reimagined there about the need for evidence in relation to adequate controls absolutely peter nuts that's one aspect that we've really seen a director's get exercised about to date because they are acutely aware that they need to be that their assertion needs to be supported by appropriate evidence and if you looked at that the company lo obligations of the tax obligations typically what we'd see happen in the past is that a lot of assurance would be taken from the skills and caliber of people in the company secretarial or the tax but tykes function rather than the underlying processes and procedures okay so now it needs to be processes and procedures and they need to be so apparent and that there's evidence for them and the directors can take comfort from that absolutely we would believe it we now need to put themselves and enter possession whether they have a sustainable robust underlying process that actively demonstrates ongoing compliance with the obligations and the approach number of our clients are taken to do that is firstly to undertake a risk assessment based on the obligations that are in the policy document that but Elaine would have articulated to say swear there is any potential gap of non-compliance do an assessment then to see do we have a control in place that mitigates that risk if not then...
