Text for CQS CPMS Policy
CQS Policy: Anti-Avoidance (update)
Purchase this policy: Stamp Duty Land Tax policy
- Change date
- 24/06/2026
- Word count
- 229
- Deployment measure
- 7/10
Rationale
Avoidance exposure now attaches directly to the firm as adviser, with acting on client instructions providing no defence. This updated section makes the prohibition explicit, requires COLP escalation within 24 hours via the Internal Compliance Notification Form, and mandates a file freeze pending review.
In recent years the Legal Ombudsman has seen examples of poor practice in this area, including non-payment of Stamp Duty Land Tax, resulting in significant consequences for homeowners who receive
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