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Russell & Russell Business Advisers Limited

Standard Terms of Business

Per­son­al clients

All engage­ments that we accept are sub­ject to the fol­low­ing stan­dard terms of busi­ness unless changes are express­ly agreed in writ­ing.
1. Pro­fes­sion­al oblig­a­tions
1.1 We are a mem­ber of the Asso­ci­a­tion of Char­tered Cer­ti­fied Accoun­tants and are sub­ject to its Code of Ethics and Con­duct which can be found at www.accaglobal.com/rulebook/code-of-ethics-and-conduct.  We will observe and act in accor­dance with the bye-laws and reg­u­la­tions of ACCA. We accept instruc­tions to act for you on this basis.
1.2 Where we become aware of errors made by HM Rev­enue & Cus­toms you give us author­i­ty to cor­rect them. We will not be liable for any loss, dam­age or cost aris­ing from our com­pli­ance with statu­to­ry or reg­u­la­to­ry oblig­a­tions.
1.3 As required by the Pro­vi­sion of Ser­vices Reg­u­la­tions 2009 (SI 2009/2999) details of the firm’s pro­fes­sion­al reg­is­tra­tions can be found at www.russell-russell.co.uk
Pro­fes­sion­al indem­ni­ty insur­ance
1.4 In accor­dance with the dis­clo­sure require­ments of the Pro­vi­sion of Ser­vices Reg­u­la­tions 2009, our pro­fes­sion­al indem­ni­ty insur­er is Pro­sure Solu­tions Ltd, The White Chapel Build­ing, 10 Whitechapel High Street, Lon­don, E1 8QS. The ter­ri­to­r­i­al cov­er­age is world­wide exclud­ing pro­fes­sion­al busi­ness car­ried out from an office in the Unit­ed States of Amer­i­ca or Cana­da and excludes any action for a claim brought in any court in the Unit­ed States of Amer­i­ca or Cana­da.
1.5 If for any rea­son cir­cum­stances arise that may result in a claim to our pro­fes­sion­al indem­ni­ty insur­ers, you give us your per­mis­sion to noti­fy them.
2. Fees
2.1 Our fees are cal­cu­lat­ed on the basis of time spent on your affairs, the lev­els of skill and respon­si­bil­i­ty involved the impor­tance and val­ue of the advice pro­vid­ed to you, and the lev­el of risk. In addi­tion, we may charge dis­burse­ments of trav­el, accom­mo­da­tion and oth­er expens­es incurred in deal­ing with your affairs.
2.2 If it is nec­es­sary for us to car­ry out work that is out­side the scope of the engage­ment cur­rent­ly in place with you, we will advise you of this in advance. Any addi­tion­al work will result in addi­tion­al fees being charged. We would there­fore like to point out that it is in your inter­ests to ensure that the infor­ma­tion you pro­vide us with is com­plet­ed to the agreed stage.
2.3 If we give you an esti­mate of our fees for car­ry­ing out any spe­cif­ic work, then that esti­mate will not be con­trac­tu­al­ly bind­ing unless we have explic­it­ly stat­ed that will be the case.
2.4 If we agree a fixed fee with you for pro­vid­ing a spe­cif­ic range of ser­vices this will be the sub­ject of a sep­a­rate agree­ment. This agree­ment will set out the peri­od which the fixed fee relates to and the ser­vices cov­ered by it.
2.5 Where we have agreed that you will pay on an invoice ren­dered basis our terms are strict­ly 30 days net.  Any queries you have on our invoic­es must be noti­fied to us with­in 21 days of receipt or we shall deem you to have accept­ed that pay­ment is due.
2.6 Where we have agreed that you will pay us on a stand­ing order basis, we will dis­cuss with you sep­a­rate­ly the amount and fre­quen­cy of pay­ments. These stand­ing orders will be applied to fees aris­ing from work agreed in our let­ter of engage­ment for the cur­rent and ensu­ing years. Where a sched­uled month­ly pay­ment is not made any fees invoiced to you that are out­stand­ing at that time will imme­di­ate­ly become due for pay­ment in entire­ty.
2.7 Where we offer you the facil­i­ty to pay your pro­fes­sion­al fees by instal­ments we do not charge any inter­est or charges except for default charges. As these terms have been agreed after 18 March 2015 this instal­ment agree­ment is not a reg­u­lat­ed cred­it agree­ment.
2.8 You may have an insur­ance pol­i­cy or mem­ber­ship of a trade or pro­fes­sion­al body that enti­tles you to assis­tance with pay­ment of our fees in some sit­u­a­tions. A par­tic­u­lar exam­ple would be assis­tance with an inves­ti­ga­tion by HM Rev­enue & Cus­toms. Unless you arranged the insur­ance through us then you will need to advise us of any such cov­er you have. Please note that you remain liable for our fees regard­less of whether all or part are liable to be paid by your insur­ers.
2.9 We reserve the right to charge inter­est on over­due accounts at the cur­rent rate under the Late Pay­ment of Com­mer­cial Debts (Inter­est) Act 1998. We also reserve the right to ter­mi­nate our engage­ment and cease act­ing if pay­ment of any fees billed is undu­ly delayed.
2.10 Inso­far as we are per­mit­ted to do so by law or pro­fes­sion­al guide­lines, we reserve the right to exer­cise a lien over all doc­u­ments and records in our pos­ses­sion.  We will only exer­cise this right where those doc­u­ments and records relate specif­i­cal­ly to the work under­tak­en on your behalf and until such times as all out­stand­ing fees and dis­burse­ments are paid in full.
2.11 In the event that we cease to act for you then you agree to meet all rea­son­able costs of pro­vid­ing infor­ma­tion to your new advis­ers. In par­tic­u­lar you agree to meet these costs where we are required by law to pro­vide infor­ma­tion to a suc­ces­sor firm.
3. Help us to give you the right ser­vice
3.1 If at any time you would like to dis­cuss with us how our ser­vice to you could be improved, or if you are dis­sat­is­fied with the ser­vice you are receiv­ing, please let us know by con­tact­ing Ross­lyn McMas­ter.
3.2 We under­take to look into any com­plaint care­ful­ly and prompt­ly and do all we can to explain the posi­tion to you. If we do not answer your com­plaint to your sat­is­fac­tion you may of course take up the mat­ter with ACCA.
3.3 In order for us to pro­vide you with a high-qual­i­ty ser­vice on an ongo­ing basis it is essen­tial that you pro­vide us with rel­e­vant records and infor­ma­tion when request­ed, reply to cor­re­spon­dence in a time­ly man­ner and oth­er­wise fol­low the terms of the agree­ment between us set out in this Stan­dard Terms of Busi­ness and asso­ci­at­ed Engage­ment let­ters. We there­fore reserve the right to can­cel the engage­ment between us with imme­di­ate effect in the event of:
• your insol­ven­cy, bank­rupt­cy or oth­er arrange­ment being reached with cred­i­tors;
• fail­ure to pay our fees by the due dates;
• either par­ty being in breach of their oblig­a­tions where this is not cor­rect­ed with­in 30 days of being asked to do so.
3.4 Should we resign or be request­ed to resign we will nor­mal­ly issue a dis­en­gage­ment let­ter to ensure that our respec­tive respon­si­bil­i­ties are clear.
4. Com­mis­sions or oth­er ben­e­fits
4.1 In some cir­cum­stances, com­mis­sions or oth­er ben­e­fits may become payable to us or one of our asso­ciates in respect of trans­ac­tions we or such asso­ciates arrange for you. If this hap­pens we will noti­fy you in writ­ing of the amount and terms of pay­ment. The fees that would be oth­er­wise payable by you will be abat­ed by such amounts. When we reduce the fees that we would oth­er­wise charge by the amount of com­mis­sion retained, we will apply the HMRC con­ces­sion which allows VAT to be cal­cu­lat­ed on the net fee after deduc­tion of the com­mis­sion. You con­sent to such com­mis­sion or oth­er ben­e­fits being retained by us or, as the case may be, by our asso­ciates, with­out our, or their, being liable to account to you for any such amounts.
5. Client monies
5.1 We may at times hold mon­ey on your behalf. Any such mon­ey will be held on trust in a client bank account, which is held sep­a­rate­ly to funds that belong to us. The client bank account will be oper­at­ed, and all funds dealt with, in accor­dance with the ACCA client mon­ey rules.
5.2 We will return monies held on your behalf prompt­ly as soon as there is no longer any rea­son to retain those funds.
5.3 To avoid exces­sive amounts of admin­is­tra­tion, inter­est will only be paid to you if the amount of inter­est that would be earned on the bal­ances held on your behalf in any cal­en­dar year exceeds £25. Any such inter­est would be cal­cu­lat­ed using the pre­vail­ing rate applied by our banker for small deposits sub­ject to the min­i­mum peri­od of notice for with­drawals. Sub­ject to any tax leg­is­la­tion, inter­est will be paid gross.
5.4 If the total sum of mon­ey held on your behalf exceeds £10,000 for a peri­od of time of more than 30 days, then the mon­ey will be placed in a sep­a­rate inter­est-bear­ing client bank account des­ig­nat­ed to you. All inter­est earned on such mon­ey will be paid to you. Sub­ject to any tax leg­is­la­tion, inter­est will be paid gross.
5.5 We will exer­cise rea­son­able skill and care to ensure that a fair rate of inter­est is earned.
5.6 Mon­ey held on your behalf in rela­tion to pro­bate ser­vices will be held in a sep­a­rate client bank account ring-fenced for legal ser­vices. This will nor­mal­ly be a sep­a­rate inter­est bear­ing client account for the estate in ques­tion.
6. Reten­tion of and access to records
6.1 Dur­ing the course of our work we will col­lect infor­ma­tion from you and oth­ers act­ing on your behalf and will return any orig­i­nal doc­u­ments to you fol­low­ing the prepa­ra­tion of your accounts and returns. You have a legal respon­si­bil­i­ty to retain these records. The law requires indi­vid­u­als, trustees and part­ner­ships to keep records in rela­tion to trad­ing or rental income 6 years from the 31 Jan­u­ary fol­low­ing the end of the tax year to which they relate. Oth­er records should be kept for 22 months after the end of the tax year they relate to. Com­pa­nies, Lim­it­ed Lia­bil­i­ty Part­ner­ships and oth­er cor­po­rate enti­ties are required to keep records for 6 years from the end of the account­ing peri­od.
6.2 Whilst cer­tain doc­u­ments may legal­ly belong to you, unless you tell us not to, we intend to destroy cor­re­spon­dence and oth­er papers that we store which are more than sev­en years old, oth­er than doc­u­ments which we con­sid­er to be of con­tin­u­ing sig­nif­i­cance. If you require reten­tion of any doc­u­ment you must noti­fy us of that fact in writ­ing.
7. Con­flicts of inter­est and inde­pen­dence
7.1 We reserve the right dur­ing our engage­ment with you to deliv­er ser­vices to oth­er clients whose inter­ests might com­pete with yours or are or may be adverse to yours. We con­firm that we will noti­fy you imme­di­ate­ly should we become aware of any con­flict of inter­est involv­ing us and affect­ing you. We have safe­guards that can be imple­ment­ed to pro­tect the inter­ests of dif­fer­ent clients if a con­flict aris­es. Where con­flicts are iden­ti­fied which can­not be man­aged in a way that pro­tects your inter­ests then we regret that we will be unable to pro­vide fur­ther ser­vices.
7.2 If a con­flict of inter­est should arise, either between two or more of our clients, or in the pro­vi­sion of mul­ti­ple ser­vices to a sin­gle client, we will take such steps as are nec­es­sary to deal with the con­flict. In resolv­ing the con­flict, we would be guid­ed by the ACCA Code of Ethics which can be viewed at www.accaglobal.com/rulebook/code-of-ethics-and-conduct .
8. Con­fi­den­tial­i­ty
Com­mu­ni­ca­tion between us is con­fi­den­tial and we shall take all rea­son­able steps to keep your infor­ma­tion con­fi­den­tial except where we are required to dis­close it by law, by reg­u­la­to­ry bod­ies, by our insur­ers or as part of an exter­nal peer review. We may, on occa­sions, sub­con­tract work on your affairs to oth­er tax or account­ing pro­fes­sion­als. Any sub­con­trac­tors we use will be bound by the same con­fi­den­tial­i­ty require­ments.
9. Qual­i­ty con­trol
As part of our ongo­ing com­mit­ment to pro­vid­ing a qual­i­ty ser­vice, our files are peri­od­i­cal­ly sub­ject to an inde­pen­dent reg­u­la­to­ry or qual­i­ty review. Our review­ers are high­ly expe­ri­enced and pro­fes­sion­al peo­ple and are, of course, bound by the same require­ments of con­fi­den­tial­i­ty as our prin­ci­pals and staff.
10. Applic­a­ble law
10.1 This engage­ment let­ter is gov­erned by, and con­strued in accor­dance with, Scots law. The Courts of Scot­land will have exclu­sive juris­dic­tion in rela­tion to any claim, dis­pute or dif­fer­ence con­cern­ing this engage­ment let­ter and any mat­ter aris­ing from it. Each par­ty irrev­o­ca­bly waives any right it may have to object to any action being brought in those courts, to claim that the action has been brought in an inap­pro­pri­ate forum, or to claim that those courts do not have juris­dic­tion.
10.2 If any pro­vi­sion in these terms of busi­ness or any asso­ci­at­ed engage­ment let­ter, or its appli­ca­tion, are found to be invalid, ille­gal or oth­er­wise unen­force­able in any respect, the valid­i­ty, legal­i­ty or enforce­abil­i­ty of any oth­er pro­vi­sions shall not in any way be affect­ed or impaired.
11. Changes in the Law
11.1 We will not accept respon­si­bil­i­ty if you act on advice pre­vi­ous­ly giv­en by us with­out first con­firm­ing with us that the advice is still valid in the light of any change in the law or your cir­cum­stances.
11.2 We will accept no lia­bil­i­ty for loss­es aris­ing from changes in the law or the inter­pre­ta­tion there­of that occur after the date on which the advice is giv­en.
12. Inter­net com­mu­ni­ca­tion
12.1 Unless you tell us oth­er­wise we will at times use email or oth­er elec­tron­ic means to com­mu­ni­cate with you.
12.2 Inter­net com­mu­ni­ca­tions are capa­ble of data cor­rup­tion and there­fore we do not accept any respon­si­bil­i­ty for changes made to such com­mu­ni­ca­tions after their despatch.  It may there­fore be inap­pro­pri­ate to rely on advice con­tained in an e‑mail with­out obtain­ing writ­ten con­fir­ma­tion of it.  We do not accept respon­si­bil­i­ty for any errors or prob­lems that may arise through the use of inter­net com­mu­ni­ca­tion and all risks con­nect­ed with send­ing com­mer­cial­ly sen­si­tive infor­ma­tion relat­ing to your busi­ness are borne by you. If you do not agree to accept this risk, you should noti­fy us in writ­ing that e‑mail is not an accept­able means of com­mu­ni­ca­tion.
12.3 It is the respon­si­bil­i­ty of the recip­i­ent to car­ry out a virus check on any attach­ments received.
13. Data Pro­tec­tion 
13.1 To enable us to dis­charge the ser­vices agreed in this engage­ment let­ter, com­ply with relat­ed legal and reg­u­la­to­ry oblig­a­tions and for oth­er relat­ed pur­pos­es includ­ing updat­ing and enhanc­ing client records and analy­sis for man­age­ment pur­pos­es, as a data con­troller, we may obtain, use, process and dis­close per­son­al data about [you / your busi­ness / com­pa­ny / part­ner­ship / its share­hold­ers / mem­bers / offi­cers and employ­ees] as described in our pri­va­cy notice. We con­firm when pro­cess­ing data on your behalf that we will com­ply with the pro­vi­sions of all rel­e­vant data pro­tec­tion leg­is­la­tion and reg­u­la­tion.
13.2 You are also an inde­pen­dent con­troller respon­si­ble for com­ply­ing with data pro­tec­tion leg­is­la­tion and reg­u­la­tion in respect of the per­son­al data you process and, accord­ing­ly where you dis­close per­son­al data to us you con­firm that such dis­clo­sure is fair and law­ful and oth­er­wise does not con­tra­vene rel­e­vant require­ments. Noth­ing with­in this engage­ment let­ter relieves you as a data con­troller of your own direct respon­si­bil­i­ties and lia­bil­i­ties under data pro­tec­tion leg­is­la­tion and reg­u­la­tion.
13.3 Data pro­tec­tion leg­is­la­tion and reg­u­la­tion places oblig­a­tions on you as a data con­troller where we act as a data proces­sor to under­take the pro­cess­ing of per­son­al data on your behalf, for instance where we oper­ate a pay­roll ser­vice for you. We there­fore con­firm that we will at all times take appro­pri­ate mea­sures to com­ply with rel­e­vant require­ments when pro­cess­ing data on your behalf. In par­tic­u­lar we con­firm that we have ade­quate secu­ri­ty mea­sures in place and that we will com­ply with any oblig­a­tions equiv­a­lent to those placed on you as a data con­troller.
13.4 Our pri­va­cy notice, which can be found on our web­site at www.russell-russell.co.uk explains how we process per­son­al data in respect of the var­i­ous ser­vices that we pro­vide.
14. The Con­tract (Third Par­ty Rights) (Scot­land) Act 2017
14.1 Per­sons who are not par­ty to this agree­ment shall have no rights under the Con­tract (Third Par­ty Rights) (Scot­land) Act 2017 to enforce any term of this agree­ment. This clause does not affect any right or rem­e­dy of any per­son which exists or is avail­able oth­er­wise than pur­suant to that Act.
14.2 The advice we give you is for your sole use and is con­fi­den­tial to you and will not con­sti­tute advice for any third par­ty to whom you may com­mu­ni­cate it. We will accept no respon­si­bil­i­ty to third par­ties for any aspect of our pro­fes­sion­al ser­vices or work that is made avail­able to them.
15. The Pro­ceeds of Crime Act 2002 and the Mon­ey Laun­der­ing Reg­u­la­tions 2017
15.1 In com­mon with all accoun­tan­cy and legal prac­tices, the firm is required by the Pro­ceeds of Crime Act 2002 and the Mon­ey Laun­der­ing Reg­u­la­tions 2017 to:
• Main­tain iden­ti­fi­ca­tion pro­ce­dures for clients and ben­e­fi­cial own­ers of clients;
• Main­tain records of iden­ti­fi­ca­tion evi­dence and the work under­tak­en for the client; and
• Report, in accor­dance with the rel­e­vant leg­is­la­tion and reg­u­la­tions.
15.2 The offence of mon­ey laun­der­ing includes con­ceal­ing, con­vert­ing, using or pos­sess­ing the ben­e­fits of any activ­i­ty that con­sti­tutes a crim­i­nal offence in the UK. It also includes involve­ment in any arrange­ment that facil­i­tates the acqui­si­tion, reten­tion, use or con­trol of such a ben­e­fit.
15.3 This def­i­n­i­tion is very wide and would include such crimes as delib­er­ate tax eva­sion, delib­er­ate fail­ure to inform the tax author­i­ties of known under­pay­ments or exces­sive repay­ments, fraud­u­lent claim­ing of ben­e­fits or grants, or obtain­ing a con­tract through bribery. Clear­ly these exam­ples are by no means exhaus­tive.
15.4 We are oblig­ed by law to report any instances of mon­ey laun­der­ing to NCA with­out your knowl­edge or con­sent. In con­se­quence, nei­ther the firms’ prin­ci­pals nor staff may enter into any cor­re­spon­dence or dis­cus­sions with you regard­ing such mat­ters.
15.5 We may use elec­tron­ic checks as part of our iden­ti­fi­ca­tion pro­ce­dures. We con­firm that these elec­tron­ic checks are not cred­it checks.
16. Gen­er­al lim­i­ta­tion of lia­bil­i­ty
16.1 We will pro­vide ser­vices as out­lined in this let­ter with rea­son­able care and skill. How­ev­er, to the fullest extent per­mit­ted by law, we will not be respon­si­ble for any loss­es, penal­ties, sur­charges, inter­est or addi­tion­al tax lia­bil­i­ties where you or oth­ers sup­ply incor­rect or incom­plete infor­ma­tion, or fail to sup­ply any appro­pri­ate infor­ma­tion or where you fail to act on our advice or respond prompt­ly to com­mu­ni­ca­tions from us or the tax author­i­ties.
16.2 You will not hold us, the own­ers of this firm and any staff employed by the firm, respon­si­ble, to the fullest extent per­mit­ted by law, for any loss suf­fered by you aris­ing from any mis­rep­re­sen­ta­tion (inten­tion­al or unin­ten­tion­al) sup­plied to us oral­ly or in writ­ing in con­nec­tion with this agree­ment. You have agreed that you will not bring any claim in con­nec­tion with ser­vices we pro­vide to you against any of the prin­ci­pals or employ­ees per­son­al­ly.
16.3 Our work is not, unless there is a legal or reg­u­la­to­ry require­ment, to be made avail­able to third par­ties with­out our writ­ten per­mis­sion and we will accept no respon­si­bil­i­ty to third par­ties for any aspect of our pro­fes­sion­al ser­vices or work that is made avail­able to them.
17. Use of our name in state­ments or doc­u­ments issued by you
You are not per­mit­ted to use our name in any state­ment or doc­u­ment that you may issue unless our pri­or writ­ten con­sent has been obtained. The only excep­tion to this restric­tion would be state­ments or doc­u­ments that in accor­dance with applic­a­ble law are to be made pub­lic.
18. Draft/interim work
In the course of our pro­vid­ing ser­vices to you we may pro­vide advice or reports or oth­er work prod­ucts in draft or inter­im form. How­ev­er, final writ­ten work prod­ucts will always pre­vail over any draft, or inter­im state­ments. Where you request it, we will pro­vide you with writ­ten con­fir­ma­tion of mat­ters stat­ed oral­ly.
19. Advice
19.1 Advice we give you oral­ly should not be relied upon unless we con­firm it in writ­ing. We endeav­our to record all advice on impor­tant mat­ters in writ­ing. How­ev­er, if you par­tic­u­lar­ly wish to rely upon oral advice we give you dur­ing a tele­phone con­ver­sa­tion or a meet­ing, you must ask for the advice to be con­firmed in writ­ing.
19.2 Unless specif­i­cal­ly instruct­ed and agreed in advance we will not assist with the imple­men­ta­tion of our advice.
19.3  We do not war­rant, guar­an­tee, or accept any respon­si­bil­i­ty or lia­bil­i­ty for the advice, ser­vices, or prod­ucts pro­vid­ed by any third par­ty. You agree to hold us harm­less and indem­ni­fy us against any claims, loss­es, dam­ages, or costs aris­ing out of, or in con­nec­tion with, your reliance upon advice giv­en or ser­vices ren­dered by any third par­ty to whom we have intro­duced you.
20. Intel­lec­tu­al prop­er­ty rights
We will retain all copy­right in any doc­u­ment pre­pared by us dur­ing the course of car­ry­ing out the engage­ment save where the law specif­i­cal­ly pro­vides oth­er­wise.
21. Pro­vi­sion of cloud-based ser­vices
21.1 Where the firm pro­vides account­ing soft­ware in the Cloud, this is pro­vid­ed by Xero (the ‘Cloud Sup­pli­er’).  The terms of use and secu­ri­ty pro­vi­sions are detailed at:
21.2 The ser­vice pro­vid­ed by the Cloud Sup­pli­er will be a dis­crete web based host­ed facil­i­ty, and you agree that access will also be pro­vid­ed to the firm and the third par­ty.
21.3 The firm can­not be held liable for any inter­rup­tion of ser­vice pro­vid­ed by the Cloud Sup­pli­er. How­ev­er, we will liaise with them to help ensure that nor­mal ser­vice is resumed as soon as pos­si­ble.
22. Invest­ment ser­vices
22.1 If, dur­ing the pro­vi­sion of pro­fes­sion­al ser­vices to you, you need advice on invest­ments, includ­ing insur­ances, we may have to refer you to some­one who is autho­rised by the Finan­cial Con­duct Author­i­ty or licensed by a des­ig­nat­ed pro­fes­sion­al body as we are not autho­rised to give such advice.
23. For­eign Account Tax Com­pli­ance Act (FATCA) and Com­mon Report­ing Stan­dards
23.1 Unless agreed specif­i­cal­ly in a sep­a­rate engage­ment let­ter, we are not respon­si­ble for your com­pli­ance with the Inter­na­tion­al Tax Com­pli­ance (Unit­ed States of Amer­i­ca) Reg­u­la­tions 2013, pro­duced as a result of FATCA.  In par­tic­u­lar, we are not respon­si­ble for the cat­e­gori­sa­tion of any UK enti­ty into either a Finan­cial Insti­tu­tion (FI) or an active or pas­sive Non-Finan­cial For­eign Enti­ty (NFFE) nor, if a Finan­cial Insti­tu­tion, for its reg­is­tra­tion with the US Inter­nal Rev­enue Ser­vice (IRS) and sub­se­quent sub­mis­sion of the required annu­al returns to HM Rev­enue & Cus­toms.
23.2 How­ev­er, if request­ed to do so we can pro­vide advice on the com­ple­tion of the forms sup­plied by Finan­cial Insti­tu­tions under these Reg­u­la­tions, or under Com­mon Report­ing Stan­dards, and used by them to deter­mine the sta­tus of an enti­ty. We can also pro­vide advice on set­ting up the appro­pri­ate sys­tems to iden­ti­fy and report on your clients or ben­e­fi­cia­ries who are for­eign cit­i­zens affect­ed by FATCA or Com­mon Report­ing Stan­dards.
24. Dis­en­gage­ment 
24.1 Should we resign or be request­ed to resign, we will nor­mal­ly issue a dis­en­gage­ment let­ter to ensure that our respec­tive respon­si­bil­i­ties are clear.
24.2 Should we have no con­tact with you for a peri­od of 6 months or more, we may issue to your last known address a dis­en­gage­ment let­ter and there­after cease to act.
24.3 We reserve the right fol­low­ing ter­mi­na­tion for any rea­son to destroy any of your doc­u­ments that we have not been able to return to you after a peri­od of six months unless oth­er laws or reg­u­la­tions require oth­er­wise.
25. Lien
Inso­far as we are per­mit­ted to do so by law or pro­fes­sion­al guide­lines, we reserve the right to exer­cise a lien over all funds, doc­u­ments and records in our pos­ses­sion relat­ing to all engage­ments for you until all out­stand­ing fees and dis­burse­ments are paid in full.