As a secure payment platform handling sensitive card data for contact centres across our global operations, we take tax compliance seriously. Paytia Limited (“Paytia”) won't tolerate tax evasion in any form — whether it falls under UK law or the law of another country. Nobody working for or with us should enter into any transaction that could amount to a tax evasion offence, or help a third party commit one.
This policy exists because of the Criminal Finances Act 2017, which made it a corporate criminal offence to fail to prevent the facilitation of tax evasion. It's straightforward: if someone associated with our business helps facilitate tax evasion and we haven't taken reasonable steps to prevent it, we're liable. So we've put those steps in place.
This policy applies to all Paytia operations worldwide, including our US entities and any customer we serve outside the UK. Tax evasion is a crime wherever it happens, and we treat the facilitation of it the same way in every country we work in.
Alongside the UK Criminal Finances Act 2017, we hold ourselves to the relevant US rules — principally IRS §7201 (attempt to evade or defeat tax) and the record-keeping and reporting duties imposed by the Bank Secrecy Act. The Criminal Finances Act already catches the facilitation of foreign tax evasion, so an employee or contractor helping someone evade US, EU, or any other tax is squarely within scope of this policy.
All staff receive the same anti-facilitation training regardless of country, and our due diligence, monitoring, and reporting procedures apply globally. Where local tax-compliance law is stricter, we follow the stricter rule. Local law adds to these commitments; it never reduces them.
We wrote this policy for three reasons: to be clear about what Paytia expects from everyone who works for us or alongside us, to help people spot the warning signs and steer well clear of anything that could be construed as tax evasion, and to make it obvious that we actually want people to speak up when something doesn't look right.
It applies to everyone connected to Paytia — employees at every level, directors, officers, agency staff, contractors, consultants, business partners, and anyone else acting on our behalf. Location doesn't matter. If you're working with Paytia, this policy covers you.
Put simply, tax evasion is the illegal non-payment or underpayment of taxes. That might mean deliberately filing a false return, misrepresenting your financial affairs to HMRC, or quietly leaving taxable income off a declaration. It's not the same as legitimate tax planning — it's dishonest, and it's a crime.
Facilitating tax evasion means knowingly helping someone else evade tax. That could be turning a blind eye, providing misleading information, or actively assisting with the mechanics of it. Even if you don't benefit personally, involvement is an offence.
The Criminal Finances Act 2017 created a specific corporate offence. It kicks in when a taxpayer (an individual or a company) criminally evades tax under UK or foreign law, someone associated with Paytia facilitates that evasion while acting in their capacity with us, and we failed to prevent it. All three have to be true.
There's a defence available if we can show we had reasonable prevention procedures in place. This policy — along with the measures described below — is part of building that defence. But more importantly, it's the right thing to do.
Prevention starts with knowing where the risks actually sit. We regularly look at our activities, relationships, and transaction flows and ask where someone could realistically create an opening to facilitate tax evasion. Because we process payments for contact centres, payment flows get the most attention.
The controls we put in place are sized to those risks. We don't run a one-size-fits-all programme — the procedures reflect what Paytia actually does and how we actually do it. That gets signed off from the top: our Board and senior management are clear that facilitating tax evasion is never acceptable, and they back that up by making it safe for anyone to raise concerns without career damage.
Before a contractor, partner, or supplier performs work on our behalf, we run appropriate due diligence on them. Everyone at Paytia gets training proportionate to their role — finance and commercial staff get more detail than someone whose job never touches tax-sensitive work. And we treat the whole thing as a living programme: we review it, we find gaps, and we close them.
Please read this policy and make sure you understand it. Preventing tax evasion isn't just a job for the compliance team — it's on all of us.
If you suspect something conflicts with this policy, or think it might in the future, tell your manager or our Chief Financial Officer straight away. Don't wait to be certain. Early reporting gives us the best chance to act.
We'd rather hear about a hundred false alarms than miss one real problem. If something doesn't feel right — even if you can't put your finger on exactly why — raise it with your line manager or the Chief Financial Officer. You don't need to be sure it's tax evasion before speaking up. That's our job to work out.
We know that raising concerns can feel uncomfortable. Nobody wants to be wrong, and nobody wants to be seen as a troublemaker. But we've been clear on this from day one: if you raise a genuine concern in good faith, we'll support you — even if it turns out there was nothing to worry about.
No one at Paytia will face any penalty for refusing to take part in tax evasion, or for reporting a suspicion that it's happened or might happen. That's a promise, not a platitude.
Our Board of Directors reviews this policy regularly to check it's still fit for purpose. When we find areas that could be stronger, we improve them promptly. As Paytia grows and our payment platform evolves, our prevention procedures will keep pace.
Approved by the Paytia Board of Directors. Reviewed and updated annually.
If you have questions about our Anti-Tax Evasion Policy or would like to report concerns, please contact compliance@paytia.com.