The Construction Industry Scheme (CIS) is a tax deduction system in the UK that involves payments made by contractors to subcontractors for construction work. Understanding the exemptions from CIS is crucial for businesses and individuals engaged in the construction sector to ensure compliance with tax obligations.
CIS and General Exemptions
The CIS covers a vast array of construction activities but there are specific scenarios where CIS does not apply. Firstly, CIS is not applicable if you are employed under the Pay As You Earn (PAYE) system as you are not considered a subcontractor in this context. This exemption ensures that individuals directly employed by the company they work for are not subjected to the CIS deductions that are typical for subcontractors.
Specific Exemptions Based on Work Nature
Significant exemptions apply based on the nature of the work being conducted. Not all tasks classified under the construction umbrella are subject to CIS. For instance, roles that are purely consultative, such as architectural services, surveying, and structural engineering calculations, are not covered by CIS. These services are exempt because they do not involve direct construction work but rather support it through expert consultation and planning.
Exemptions for Non-Construction Organizations
Organizations whose primary business is not construction, but who occasionally contract construction work, also benefit from exemptions under certain conditions. This includes entities such as housing associations or landlords managing property portfolios. These organizations are exempt from CIS if their annual expenditure on construction does not exceed £3 million. This threshold helps to differentiate between occasional construction work and regular construction activity that would typically fall under CIS.
Exemptions Related to the Scale and Scope of Work
For both contractors and subcontractors, any work on their own property that does not exceed £1,000 in value, excluding materials, is exempt from CIS. This exemption is designed to minimize administrative burdens for small-scale construction or maintenance works carried out by businesses or individuals on their own properties.
Situational Exemptions
Certain other specific exemptions are based on the circumstances or location of the work. For example, work paid for by charities or conducted by educational institutions like schools, where the work is funded directly by the governing body or head teacher, is not subject to CIS. This exemption is aligned with the broader aim of supporting educational and charitable activities without the additional financial burden of tax deductions.
Upcoming Reforms and Changes
Recent reforms, effective from April 2024, have introduced stricter compliance measures, particularly concerning VAT obligations under CIS. These changes are part of a broader effort to enhance tax compliance in the construction sector and ensure that all parties meet their financial obligations fairly and consistently.
Understanding who is exempt from the CIS is essential for compliance and financial planning in the construction industry. The exemptions are designed to reduce unnecessary administrative burdens while ensuring that substantial construction activities contribute appropriately to tax revenues. The next part of this article will delve deeper into how these exemptions are applied in practice, providing further clarity on managing CIS obligations effectively.
Deemed Contractors and Their Exemptions
Deemed contractors are entities that do not primarily engage in construction but spend more than £3 million on construction in a 12-month period. These include local authorities, housing associations, and government departments. They must monitor their construction spend closely as they fall under CIS regulations once their expenditure exceeds the threshold. However, CIS rules are slightly relaxed for these entities when the construction is for their own use and not intended for sale or rental, providing a strategic exemption that aligns with their operational needs.
VAT and Gross Payment Status Exemptions
Changes to the CIS from April 2024 emphasize the need for subcontractors to demonstrate VAT compliance to obtain and maintain Gross Payment Status (GPS). This status allows subcontractors to receive payments without deductions. The update signifies a tightening of compliance measures, potentially reducing the number of subcontractors eligible for this exemption due to heightened scrutiny of their tax affairs.
Impact of Changes on Exemptions
The reforms aim to streamline the administration of CIS and ensure that all parties meet their tax obligations. These include new rules making minor VAT compliance failures less likely to affect a subcontractor's GPS. This adjustment is particularly important for subcontractors who may face administrative challenges and ensures that penalties are proportionate to the oversight.
Special Cases: Charitable and Educational Institutions
Charitable organizations and educational institutions continue to enjoy exemptions from CIS for construction work paid directly by these entities for their own use. This exemption supports these organizations by freeing up more resources for their primary educational or charitable activities instead of being allocated towards tax burdens.
Lesser-Known Exemptions and Clarifications
Certain less obvious exemptions also apply under CIS. For instance, the scheme does not cover the manufacture or delivery of building materials to the construction site, nor does it include the work of making or delivering components that are prepared offsite. This distinction is crucial for suppliers and manufacturers who operate in the construction industry but do not engage in onsite construction activities.
Navigating CIS with Exemptions
For contractors and subcontractors, understanding and applying CIS exemptions is crucial for effective financial and project management. Here's a closer look at how to navigate these regulations:
Verification Process: Contractors must verify whether their subcontractors are registered for CIS and check their eligibility for exemptions or Gross Payment Status (GPS). This includes confirming VAT compliance under the new rules, ensuring that all parties are clear on their tax responsibilities.
Record Keeping and Reporting: Maintaining accurate records is vital. This includes details of all transactions, exemptions applied, and CIS deductions made or foregone. Accurate record-keeping ensures compliance and facilitates easier resolution of discrepancies with HMRC.
Consulting with Specialists: Given the complexity of the regulations and the severe penalties for non-compliance, consulting with tax specialists or using dedicated CIS software can help manage obligations more effectively. This is especially important for deemed contractors who must monitor their construction expenditures closely.
Compliance Tips for Post-2024 CIS Regulations
With the recent updates to the CIS regulations, here are some tips to help contractors and subcontractors stay compliant:
Stay Informed: Keep up-to-date with any changes in CIS regulations. HMRC frequently updates its guidelines and requirements, and being aware of these changes can prevent compliance issues.
VAT Compliance: Under the new rules, demonstrating VAT compliance has become more crucial for maintaining GPS. Ensure that all VAT returns are accurate and filed on time to avoid disruptions in payment processes.
GPS Maintenance: Subcontractors with GPS should regularly review their status to ensure they continue to meet the necessary compliance standards. This includes maintaining up-to-date records on all tax obligations, including VAT, corporation tax, and PAYE.
Final Thoughts
The CIS scheme plays a crucial role in the UK construction industry, helping to ensure that tax obligations are met across the board. By understanding and applying the exemptions available, contractors and subcontractors can not only comply with the law but also optimize their tax and financial planning. As the industry continues to evolve, particularly with the technological and regulatory changes, staying informed and proactive in tax management will be key to successful navigation of the CIS landscape.
What Specific Exemptions are Available in the UK Based on Work Nature?
In the UK, the Construction Industry Scheme (CIS) governs how payments to subcontractors for construction work must be handled for tax purposes. However, not all work falls under the CIS, and there are specific exemptions based on the nature of the work. These exemptions are crucial for businesses to understand as they navigate the complexities of compliance with tax regulations.
Understanding CIS Exemptions Based on Work Nature
The CIS primarily targets construction operations, but there are defined categories of work that are specifically exempt, often due to their professional, advisory, or ancillary nature relative to actual construction.
1. Professional Services
Certain professional services that do not involve physical construction activities are exempt from CIS. These services include:
Architecture and Surveying: Tasks such as drafting architectural plans, conducting surveys before construction begins, or providing architectural advice.
Engineering Consultation: Services involving civil, structural, or other engineering disciplines where the primary role is consulting and planning rather than executing construction.
Project Management: Overseeing a construction project without directly engaging in physical construction activities.
2. Manufacturing and Delivery of Materials
The manufacture and delivery of construction materials are not covered by CIS unless the delivery is linked with installation. Here are specific examples:
Manufacture of Building Components: Production of prefabricated elements like beams, panels, or other building parts.
Delivery of Materials: Supplying construction sites with materials without any associated installation services.
3. Miscellaneous Services
Some services are related to construction sites but are considered too peripheral to be included under CIS. These include:
Scaffolding Hire: Providing scaffolding without involving labor for its erection.
Site Facility Services: Running canteen services, providing security, or operating waste management on construction sites.
Equipment Hire: Renting out construction equipment without providing operators.
4. Work on Non-Construction Sites
Services performed in settings that are not construction sites typically fall outside the scope of CIS:
Software Installation: Installing software or systems, such as computer networks or security systems, especially when not integrated into the construction but added post-completion.
Artistic Work: Work related to artistic installations that do not alter the structure of buildings.
5. Specific Exemptions for Certain Settings
Work conducted under specific conditions or in certain environments may also be exempt:
Work for Homeowners: Direct engagement by homeowners for work on their private residence typically does not require CIS compliance.
Charitable Work: Construction or repair work carried out directly by charities or for charitable purposes can be exempt from CIS.
Compliance and Considerations
To properly apply these exemptions, businesses must:
Document the Nature of Work: Maintain clear contracts and descriptions of the services provided to establish eligibility for CIS exemptions.
Communicate with HMRC: Ensure that all exemptions are correctly registered and understood by tax authorities to avoid penalties.
Educate Subcontractors: Inform subcontractors about the nature of their work and its CIS status to ensure correct handling of deductions and compliance.
Understanding which specific exemptions are available based on the nature of work under the CIS is essential for businesses in the UK construction industry. This not only helps in ensuring compliance with tax regulations but also aids in strategic business planning and financial management. By recognizing the boundaries of CIS, companies can more effectively manage their projects, engage the right professionals, and allocate resources efficiently.
What CIS Situational Exemptions are Available in the UK?
The Construction Industry Scheme (CIS) in the UK imposes rigorous regulations on payments made under construction contracts, specifically those payments made from contractors to subcontractors. However, there are situational exemptions where the CIS does not apply, designed to accommodate specific circumstances or types of work that do not align with the typical construction activities envisioned under the scheme. These exemptions are crucial for businesses to understand to ensure compliance while also optimizing their tax liabilities.
Key Situational Exemptions in the CIS
1. Work for Homeowners
One of the most straightforward exemptions applies when subcontractors are engaged directly by homeowners for construction work on their primary residence. This exemption is intended to simplify the process for homeowners managing personal construction projects without the complexities of CIS paperwork.
2. Charitable and Public Sector Work
Work carried out directly for charities or for certain public bodies—like local councils or schools—can be exempt from CIS if these bodies are not in the business of doing construction work regularly. This exemption aims to reduce the administrative burden on non-profit and public organizations.
3. Minor Work
Minor construction work costing less than £1,000 (excluding VAT and materials) is also exempt from CIS. This is designed to help small businesses and self-employed individuals avoid cumbersome reporting requirements for relatively insignificant amounts of work.
4. Overseas Contractors
Non-UK businesses doing construction work in the UK can find themselves exempt from CIS if they do not have a permanent establishment or base in the UK. This exemption is crucial for international firms undertaking short-term projects in the UK.
5. Manufacturing and Design Work
The scheme exempts those whose role is solely to manufacture or design construction materials or components, provided these activities do not include installation. Similarly, professionals such as architects and surveyors who only provide planning and design services are outside the scope of CIS.
6. Emergency Repair Work
Emergency repair work, particularly when it is unplanned and urgent, can sometimes be exempt from CIS. This is particularly relevant where safety or security is at risk, allowing repairs to be made swiftly without the need for immediate CIS compliance.
7. Non-construction Ancillary Services
Services ancillary to construction work, such as the running of a works canteen, provision of security, or other non-construction site services, are exempt. This delineation ensures that CIS is focused solely on construction activity and not on peripheral services.
Compliance and Strategic Considerations
Understanding these exemptions can significantly affect how a project is structured and managed from a financial and regulatory perspective. Businesses and contractors need to:
Document Everything: Maintaining thorough records that clearly delineate the nature of the work and its qualification for any exemptions is essential.
Seek Advice: Given the complexities of the CIS regulations and the penalties for non-compliance, consulting with a tax professional or a CIS expert is advisable.
Educate Partners and Subcontractors: Ensuring that all parties involved in a project are aware of the CIS requirements and any applicable exemptions can prevent misunderstandings and ensure smoother project execution.
The situational exemptions available under the CIS are designed to make the scheme more adaptable to the varied nature of construction and related activities. For businesses engaged in the construction industry, an in-depth understanding of these exemptions not only aids compliance but also optimizes financial and operational efficiency. By leveraging these exemptions, companies can better navigate the regulatory landscape of the UK's construction industry, ensuring that projects proceed smoothly while minimizing unnecessary tax burdens.
What Documentation Should Subcontractors Provide to Contractors to Prove Exemption from CIS?
When subcontractors in the UK wish to prove their exemption from the Construction Industry Scheme (CIS), it's crucial they provide the correct documentation to contractors. This process is designed to ensure all parties meet the legal requirements set out by HM Revenue and Customs (HMRC), thereby avoiding unnecessary deductions and maintaining compliance with tax regulations.
Understanding CIS and Exemption Criteria
Before delving into the specific documents required, it's important to understand under what circumstances a subcontractor can be exempt from CIS. Generally, exemptions apply when the subcontractor is not performing what is legally defined as construction work under CIS regulations, or when they work under certain organizational or financial thresholds.
Essential Documentation for Proving CIS Exemption
1. Proof of Employment Status
Subcontractors must prove that they are not self-employed but are instead employees under the PAYE (Pay As You Earn) system. This involves providing documentation such as a P60 or recent payslips that indicate their tax is being handled by their employer.
2. Business Structure and Registration Documents
If the subcontractor operates as a limited company or partnership that is automatically exempt from CIS, they need to provide their company registration details and, potentially, evidence of their exemption status directly from HMRC.
3. VAT Registration Certificate
For subcontractors who are exempt because they supply only materials or certain non-construction services, a VAT registration certificate can help prove that their primary business activity does not fall under the CIS.
4. Unique Taxpayer Reference (UTR)
A UTR number is not direct proof of exemption but is necessary for identification when dealing with HMRC. Subcontractors who claim exemption will often need to reference their UTR when submitting proof or discussing their status with contractors.
5. Work Contracts or Agreements
Detailed contracts or agreements that outline the nature of the work can serve as proof that the activities performed do not fall within the scope of CIS. These documents should clearly state the services provided and, ideally, specify that the work is non-construction related when applicable.
6. Evidence of Working for End-Users
In cases where subcontractors are working directly for end-users (e.g., private homeowners), documentation that demonstrates the relationship and the nature of the project can exempt them from CIS. This can include contracts, invoices, or written agreements.
7. Professional Certifications or Qualifications
Subcontractors performing work that requires specific professional qualifications, such as architecture or surveying, which are exempt from CIS, should provide copies of their professional certifications to prove that their services do not include manual construction work.
8. Letters from Legal or Financial Advisors
Professional letters from accountants, solicitors, or tax advisors clarifying the subcontractor’s exemption status based on their business operations or the nature of their contracts can provide authoritative evidence to contractors.
Practical Tips for Subcontractors
Keep Records Updated: Ensure that all documents are up-to-date and readily available to present to contractors or HMRC when required.
Understand CIS Rules: Regularly review the CIS regulations as they apply to your situation. HMRC provides comprehensive guides and updates that can help determine if you qualify for an exemption.
Communicate Clearly: When providing documents to a contractor, explain what each document represents and how it supports your exemption claim. Clear communication can prevent misunderstandings and delays.
Subcontractors looking to prove their exemption from the CIS need to be meticulous in gathering and presenting the correct documentation. By understanding the requirements and preparing accordingly, subcontractors can streamline their interactions with contractors, ensuring compliance and avoiding unnecessary CIS deductions. This proactive approach not only aids in maintaining legal compliance but also supports smoother financial operations for both parties involved.
Case Study: Navigating CIS Exemptions for Small-scale Construction Work
Background
Oliver Martin, a contractor based in Surrey, UK, encountered a scenario that required careful navigation of the Construction Industry Scheme (CIS) exemptions. Oliver's company specializes in residential renovations and occasionally takes on small projects such as home extensions and refurbishments. In June 2024, he was approached by a homeowner for a small kitchen refurbishment project. The project involved some minor structural adjustments and the installation of new kitchen units with a total cost slightly under £1,000, excluding materials.
The Challenge
Oliver needed to determine if this project would require CIS deductions or if it fell under the exemptions provided for small-scale works. He was aware that incorrect handling of CIS procedures could lead to compliance issues and penalties from HMRC.
Step-by-Step Process
Project Assessment: Oliver assessed the project details against CIS criteria. He found that work costing less than £1,000 (excluding materials) qualifies for CIS exemption if it's a standalone project.
Consultation with a CIS Agent: To ensure compliance, Oliver consulted a CIS specialist. The agent confirmed that the project indeed qualified for an exemption but recommended officially notifying HMRC to avoid any future disputes.
Documentation: Oliver gathered all necessary documentation, including the homeowner's contract, detailed cost breakdowns, and correspondence confirming the project's scope and budget. This documentation was crucial for proving the exemption should HMRC query the project.
Notification to HMRC: Following his CIS agent's advice, Oliver used HMRC's online services to notify them about the project and its exemption status. This step is essential to maintain transparency and compliance with tax obligations.
Project Execution: With the exemption confirmed, Oliver proceeded with the project without applying CIS deductions to the payments he made to his subcontractors.
Final Compliance Check: After project completion, Oliver reviewed all financial transactions and correspondence related to the project to ensure everything was reported correctly in his CIS returns and company accounts.
Outcome
The project was completed on time and within budget. Oliver’s proactive approach in handling CIS exemption not only ensured compliance but also maintained good standing with HMRC. This case highlights the importance of understanding CIS regulations and taking advantage of available exemptions to optimize tax liabilities and administrative burdens.
This real-life scenario underscores the critical need for contractors to stay informed about CIS regulations and potential exemptions. By doing so, they can avoid unnecessary deductions, streamline their operations, and focus on delivering quality work without the overhead of complex tax compliance issues. Contractors should regularly consult updated guidelines from sources like HMRC or professional advisory services to keep abreast of any changes in the legislation.
How Can a CIS Tax Return Accountant Help You With CIS Exemptions?
In the complex landscape of the UK's Construction Industry Scheme (CIS), managing tax obligations can be a daunting task, particularly when it comes to understanding and applying for CIS exemptions. This is where a CIS tax return accountant becomes invaluable. Specialized in the nuances of construction taxes, these professionals offer a range of services designed to ensure compliance while optimizing tax benefits.
Understanding the Role of a CIS Tax Return Accountant
A CIS tax return accountant specializes in the tax affairs of those operating within the construction sector, particularly focusing on the CIS. Their expertise extends to understanding detailed legislative requirements, which can be pivotal in avoiding overpayments and penalties due to non-compliance.
Services Provided by CIS Tax Return Accountants
Identification of Applicable Exemptions: CIS tax return accountants help identify which parts of your construction activities may be exempt from the CIS. For instance, certain types of work such as architecture, surveying, and some types of repairs may not require CIS deductions. Understanding these exemptions can prevent unnecessary deductions from payments to subcontractors.
Assistance with Registration and De-registration: They assist businesses in determining whether they need to register under CIS or if they qualify as a deemed contractor, which requires careful monitoring of expenditure on construction operations. They also manage the de-registration process for those no longer covered by CIS due to changes in their business operations.
Guidance on Mixed Contracts: In cases where contracts include both CIS and non-CIS work, accountants provide guidance on how to handle payments correctly to ensure compliance and optimize tax liabilities.
Preparation and Filing of CIS Returns: They handle the monthly submission of CIS returns to HMRC, ensuring all information is accurate and submitted on time. This includes calculating the correct amount of deductions to be made from payments to subcontractors and reporting the same to HMRC.
Claiming Refunds: If too much tax has been deducted, CIS tax return accountants can help reclaim any overpayments. This is particularly relevant for subcontractors who may have had excessive deductions taken from their pay.
Advising on Compliance and Record-Keeping: Keeping accurate records is essential under CIS. Accountants ensure that all necessary documentation is maintained, from contracts and invoices to payment and deduction statements, to support any claims or deductions and to prepare for potential audits by HMRC.
Handling Disputes with HMRC: Should discrepancies arise, such as disputes over deductions or status, a CIS tax return accountant can represent your business in discussions with HMRC, providing expert advice and negotiating on your behalf.
Training and Updates: These professionals also provide training for your accounting team on CIS processes and keep you updated on legislative changes that might affect your tax liabilities.
Real-Life Benefits of Engaging a CIS Tax Return Accountant
Consider the hypothetical scenario of a construction firm facing complications in distinguishing between taxable and exempt CIS activities. A CIS tax return accountant could step in to analyze their contracts, ensuring that exemptions are properly applied for activities such as the installation of security systems, which might not necessarily require CIS deductions depending on the context. By doing so, the accountant not only ensures compliance but also aids in financial planning by optimizing tax liabilities.
The intricacies of the CIS can pose significant challenges to those within the UK construction industry. A CIS tax return accountant plays a crucial role in navigating these challenges, offering tailored advice that ensures both compliance with the law and optimization of tax payments. For businesses looking to secure their financial footing while adhering to CIS regulations, engaging with a knowledgeable accountant is not just beneficial; it's essential for sustainable operation.
FAQs
Q1: How can subcontractors check their current CIS status and gross payment status with HMRC?
Subcontractors can check their CIS status and whether they have Gross Payment Status by logging into their HMRC online account, where they can view their tax affairs and CIS status in real time.
Q2: Are there any specific insurance requirements for contractors registered under CIS?
Yes, contractors typically need to have public liability insurance as a basic requirement. Depending on the nature of the work, additional cover such as employers' liability insurance may also be required.
Q3: What documentation should subcontractors provide to contractors to prove exemption from CIS?
Subcontractors should provide documentation such as a unique taxpayer reference (UTR) and evidence of self-employment status. If claiming exemption due to business type or nature of work, relevant certifications or evidence of non-construction activities should be provided.
Q4: How frequently do CIS regulations change, and where can one find the most current information?
CIS regulations can change annually with the budget announcements or as part of specific tax law amendments. The most current information can be found on the HMRC website or through tax advisories published by reputable accounting firms.
Q5: Can a subcontractor request a refund for over-deductions under CIS, and what is the process?
Yes, a subcontractor can request a refund for over-deductions. The process involves submitting a claim to HMRC through their online account, providing details and evidence of the over-deduction.
Q6: How does CIS apply to construction projects that span multiple tax years?
CIS applies to each payment made, so it spans across tax years based on when the payments are actually disbursed. Contractors must handle deductions and reporting based on the tax year in which the payment is made.
Q7: Are foreign subcontractors working in the UK covered by CIS?
Yes, foreign subcontractors working in the UK are covered by CIS and must register with HMRC. They are subject to the same rules as UK-based subcontractors.
Q8: What penalties exist for failing to comply with CIS regulations?
Penalties for non-compliance can include fines, interest on late payments, and in severe cases, loss of Gross Payment Status or legal action.
Q9: How does CIS interact with VAT reverse charge in the construction industry?
CIS and the VAT reverse charge interact in that both affect how payments are processed between contractors and subcontractors. CIS handles tax deductions on payments, while the VAT reverse charge affects how VAT is accounted for, with the customer generally handling the VAT instead of the supplier.
Q10: What specific steps should contractors take to verify subcontractors before making payments under CIS?
Contractors must use the HMRC online service to verify subcontractors, checking if subcontractors are registered for CIS and their tax status, to determine the correct rate of deduction.
Q11: Is there an appeal process if a subcontractor disagrees with a deduction made under CIS?
Yes, subcontractors can appeal against CIS deductions they believe are incorrect. The appeal should be lodged with HMRC, detailing the reasons for the disagreement.
Q12: Are there exemptions from CIS for emergency repair work on properties?
Emergency repair work may still fall under CIS if performed by a subcontractor, but specific circumstances such as direct engagement by a non-construction firm might lead to exemptions.
Q13: How can subcontractors maintain their Gross Payment Status effectively?
Subcontractors must ensure timely and accurate tax returns, maintain compliance with all HMRC regulations, and regularly review their financial affairs to ensure no defaults that could affect their status.
Q14: What are the consequences of incorrect CIS deductions by contractors?
Incorrect CIS deductions can lead to financial discrepancies, disputes, and potential penalties from HMRC for both contractors and subcontractors if not resolved promptly.
Q15: Can CIS deductions be adjusted retrospectively?
Yes, CIS deductions can be adjusted retrospectively if errors are identified. Both contractors and subcontractors need to inform HMRC and adjust their tax records accordingly.
Q16: What training or resources are available to help contractors and subcontractors understand their responsibilities under CIS?
HMRC provides webinars, detailed guides, and workshops. Additionally, many professional bodies and industry associations offer training and resources on CIS compliance.
Q17: How does CIS affect the cash flow of subcontractors?
CIS can significantly affect the cash flow of subcontractors due to the upfront tax deductions, which may restrict the immediate availability of funds from payments.
Q18: What digital tools are available to manage CIS compliance more efficiently?
Various software solutions are available that integrate CIS management features, such as automatic deduction calculations, verification checks, and direct reporting to HMRC.
Q19: Are there specific CIS guidelines for subcontractors providing only labor, without supplying materials?
Yes, CIS deductions are typically focused on the labor component of a contract. If a subcontractor provides only labor, the entire payment may be subject to CIS deductions unless exempt.
Q20: What are the record-keeping requirements for CIS for both contractors and subcontractors?
Both contractors and subcontractors are required to keep detailed records of all CIS transactions, deductions, and communications with HMRC for at least three years to ensure compliance and facilitate any necessary audits or reviews.
Comments