Search

Site Search A-Z Index

IN THIS SECTION

Paper Delivered by Liam Irwin, Collector-General to the Irish Taxation Institute Annual Conference Galway, 24 April 2004

When it comes to transactions - the theme of this conference - there is probably no single organisation with which you have more transactions than with Revenue. You and your firms transact with us virtually every working day of the year, and now via ROS and our other online services, potentially you can have transactions with us 365 days in the year - perhaps, it being a leap year, even 366 days!

And of course the converse applies - especially for business taxes - most of our daily transactions involve you and your colleagues, either directly, or jointly with your clients.

The effectiveness of these transactions is hugely important for both of us -
Our level of our service to you
· The timeliness and accuracy of the response you get when you phone or write to us.
· The speed, reliability and accuracy of payment and filing both through ROS and the various other methods available
· The accuracy of our assessments
· The provision of quality information through our website and otherwise
· Our willingness to assist where your client has a genuine difficulty in meeting his/her tax obligations.
These all have an important bearing on your cost structures, on the cost of your services to your clients, and on the overall effectiveness of the service you provide to your clients. We are very conscious of this, and even though we may not always get it right, our objective is to reduce these overheads, to our mutual advantage.
Transacting with each other at a high level, through TALC and through the various TALC sub-committees, and also using many other formal and informal channels is also influential in shaping tax administration in Ireland. The successful implementation of Pay & File is just one example of this type of consultation.

Some of our other transactions with each other are potentially more confrontational. Compliance activity, enforcement, audit, prosecution - these are the areas where Revenue must focus relentlessly, and where our activities will be of serious concern to you clients, albeit mostly to those clients who have every reason to be concerned.

But I firmly believe that you the tax practitioners, and we, Revenue, share responsibility in partnership in combating non-compliance.
You have a role in advising all your clients, including those who are in arrears with returns and payments and those who Revenue is seeking to penalise, perhaps even prosecute, for various episodes of tax evasion.
But your ultimate objective is surely a shared objective with us - to ensure that your client is compliant now and into the future, and that any omissions of the past are made good.
On a global basis, I hope we are agreed that what we all want is a fair and equitable tax system, where everyone pay pays his or her due share - that we have a tax system which is perceived by the great majority of citizens as fair, and in which non-payment, evasion or unjust avoidance is generally perceived to be a fraud by the perpetrator on society.

I hope over the next 25 minutes or so to give you an insight into how I see our dealings with each other evolving into the future. This is shaped by several developments, most notably by the potential unleashed through the Revenue Restructuring programme which has made huge strides in the past several months, by IT developments, by improved customer service with its emphasis increasingly on self service, and through TALC.

TALC
I am going to start with the last mentioned , TALC. I have the honour of being its Chairperson this year. Frank Daly speaking to you last year, underlined the significance Revenue attaches to maintaining and developing professional relationships with the Institute, with TALC and with other Representative groups. As Frank said then, "co-operation and mutual understanding are far more productive than antagonism. We can learn from each other without compromising either side. In the process we can bring clarity and common sense to what is an extremely complex but absolutely fundamental area of national, business and personal life".

I have no doubt but that TALC has been of tremendous benefit in shaping many initiatives in tax administration over they years. Just by way of examples, the structure of Pay & File, many features in ROS, the audit code of practice and the operation of BIK under PAYE have all benefitted from consideration and negotiation at TALC. Similarly, the buy-in by your Institute and the other TALC participants was hugely influential in the success of ROS.

I believe TALC, and its various specialist sub-committees, works well because of the calibre of the representatives nominated by various participating bodies. I know that you nominate some of your best people from your councils and professional staff to TALC - that's what makes the process work effectively. In Revenue, our main representation is also at a very senior level, generally Divisional Head/Assistant Secretary level. We are committed to continuing our representation at this senior level - indeed we have in the past two years increased our commitment to the process through the nomination of a manager, currently Mick Gladney, who is available to hear and hopefully resolve your concerns outside of the formal meeting structure.

COLLECTOR-GENERAL
I suppose I can hardly dare come here as Collector-General, and not talk to you about some of the developments and concerns in my own area of responsibility.

Collector-General is of course an endearing title to everyone who hears it - if I was younger the perfect chat-up line. And it's even more endearing to anyone who gets a letter from me.

Though we are held in some respect. One of your colleagues told me last night that I run the most successful mail order business in the country!

And we get mentioned even in the bible. My predecessors, even got honourable mention in the New Testament.
"The Pharisee stood and prayed thus with himself, "God, I thank thee that I am not like other men, extortioners, unjust, adulterers, or even like this tax collector".

I do take the job of collecting tax very seriously, though I am not sure I would take it as far as what I am told is the unofficial motto of the IRS
"We have what it takes to take what you have".

And, one for those intending to sup at the bar tonight. I recently came across a quotation from one Robert Heinlein warning

"Be wary of strong drink........ It can make you shoot at tax collectors.... And miss!"

But one other quote I came across recently may indicate that scripture is not all against the unfortunate tax collector.

"If the Lord loveth a cheerful giver, how he must hate the taxpayer"

You won't be surprised when I tell you that the key element of my job is collecting money - lots and lots of it! Just to give you a feel for it, there were only two working days last year when we our single day receipts did not reach €60 million and we had one day when receipts exceed €1 billion. This year Charlie McCreevey expects me to deliver 40,000 million €, €40 billion, so in that context a steady cashflow is a necessity.

Unfortunately, of course, it is not all about accepting and receipting the money that comes in. The concept of self-assessment has not quite yet reached that stage. If it ever does, the tax industry will become a simple, and significantly less labour intensive industry.

You will also hardly be surprised to hear that all of what we are owed does not collect itself, indeed some of it is very reluctant to get collected. So there has to be a harder edge to our business. This is the debt management compliance function, and is where the largest part of our resources are directed. Our dual objectives are to achieve the highest levels of payment of tax in the month in which it is due, and to avoid the build up of arrears. We have been reasonably successful in these tasks - the levels of compliance we achieve are well in line with international comparators, and out debt at around 3% of annual collection compares very well with the situation just before when Self Assessment was introduced when the debt was almost 40% of annual collection

But , but but..........
We still have mountains to climb. Compliance is good and improving. BUT the number of taxpayers who pay late is still unacceptably high, and for smaller business, where we have devoted less attention, it is a cause for concern. And there are cases which contrive through not making returns, especially in VAT, to hide very big liabilities until the company has vanished and collection had become difficult if not impossible.

These are my challenges, and the challenges of the entire Revenue organisation. Revenue restructuring did not have a huge structural impact on the Collector-Generals office, although we had some changes such as the transfer of responsibility for tax-clearance to the Regions and the assumption by us of the main customer service responsibility for PAYE employers. But we are forging stronger links between the activities of CG's and the Regions in relation to debt management, and greater clarity of roles, with CG essentially responsible for current compliance and the regions concentrating mostly on more intractable arrears.

While the Revenue restructuring programme did not change the make up of the Division, we are conducting a process of ongoing change, with the specific intention of freeing up more and more resources to concentrate on debt management compliance work. In the past 5 months we have, through internal restructuring and by reaping a good IT efficiency dividend, increased the number of general debt management units from 10 to 13, and I expect that this number will increase to 15 before the end of the year. In effect we will have a 50% bigger resource tackling slow and non-compliance. It is a resource shift which will see a big increase in the number and timeliness of our interventions. The objective is to get more and more of our taxpayers to realise that not paying the taxman, or indeed paying the taxman late is an expensive option, and that there is virtual certainty that non-compliance will be tackled, and punished for as long as it persists. Perhaps, indeed, use of the term taxpayer for some of these reluctant customers is a misnomer - rest assured it is the ambition of the Collector-General that the term can be justly applied.

To quote Bart Simpson - "I will torment the non-believers"

I don't intend to give you a full tour of the Collector-General's business, that would take of my 40 or so minutes, but there are one or two other business issues I will briefly advert to.

Our internal restructuring is addressing the service level of our call centre. Especially during the busy periods around pay and file, and the P35 filing season, I acknowledge that our service to you and your clients was less than optimum. This month we are restructuring that service, dynamically linking separate services in Limerick and Nenagh, and increasing the overall resource. I hope this will result in a much improved quality of service. Also, just to mention, we had become a service industry for some of your colleagues, often several times a year, at accounts preparation time, P35 time, VAT RTD time, when we received calls requesting literally dozens of taxpayer statements for multiple taxheads. This is not the purpose of our call centres and we now accept only 3 statement requests in a call from a practitioner. The primary delivery route now for this type of service is through ROS - the self service option if you like. We will provide multiple statements if you write to us, but ROS is by far the quickest and cheapest route for all of us.

Another issue I want to refer to is the abuse of limited liability, manifested through Phoenix companies, and also increasingly through networks of related companies, not classically Phoenix in character, but clearly intent on abusing company law to evade the payment of tax. This issue was starkly highlighted by the Comptroller and Auditor General in his report for 2001, and was already a source of serious concern to us. Typically some of these companies are ceased with accumulated debts, others are still trading, some are struck off but still in business, and virtually all of them feature slow or non-payment. We have now instituted procedures to ensure that every serious arrears case, and every liquidation case, is examined for the presence of related entities, such as other companies with the same directors. This "comonality check" as it has come to be known checks for other entities be they living or dead or in that legal limbo of struck-off-land. I have increased substantially the dedicated resource focused on this work, and I plan to devote more attention and more resource to it in the coming months. Our approach will be hard in these cases... we will not hesitate to seek the liquidation of all the related non-compliant companies in a "group", and we will be actively in support of court moves by liquidators to have the individuals behind these companies restricted under the companies acts. And of course, we will not hesitate to report this type of abuse to the Director of Corporate Enforcement.
Just one last thing in relation to my own area, Debt collection is a difficult business, and we do frequently have to make hard decisions, mostly to enforce debt through the sheriffs and the courts, and sometimes if we have to, through liquidation, bankruptcy, possession of property or seeking commital. But we do understand that sometimes a business experiences cash flow difficulties and is unable to pay a liability as it falls due. We try as best we can to distinguish genuine hardship from deliberate late or non-compliance. Where a business in difficulty approaches us, we do try to be helpful. We can in appropriate cases do our best to help the business survive - through for example instalment arrangements, even deferred payments - though will be an interest cost in this, but the hassle and cost of enforcement is avoided. The important thing in this type of situation - I've said it over and over at conferences and seminars, but I'm not sure it is a message that gets through - if in difficulty contact us, agree a course of action. Ignoring a problem is almost certainly going to involve enforcement costs and hardship, and our flexibility to be understanding is much more limited when legal remedies for the collection of a debt are at an advanced stage. Please, please do try to get this message across to you colleagues and your clients - ignoring a tax debt problem is not a solution, talk to Revenue, we are prepared to listen.

Revenue Restructuring
For most people in Revenue the biggest event in recent years was Revenue Restructuring. It was a long time in the making, over 5 years from when it was first conceived , and it followed two years of very detailed planning and piloting. It finally came to be in what was known as 'Big Bang' over the October holiday weekend in 2003.

I won't bore you with the detail, but the amount of planning that went into the project was phenomenal. There were so many different aspects to the project in so many different spheres- office accommodation, negotiation with unions, assignment of personnel, regrading of substantial numbers of staff, changes in IT, and changes in IT access for staff leaving soon to be defunct jobs and districts on Friday afternoon to return to entirely new jobs and districts on Tuesday morning - to say the whole task was daunting is a vast understatement.

'Big Bang' was intended to be a bang heard internally, but as regards customer service impact, in IT parlance is was intended to be 'invisible to the user', i.e. you and your clients. Unfortunately, I think many of you experienced some of the tremors too, mostly difficulties with who to contact, and in getting through to our new offices on the telephone.

It is impossible to make an omelette without breaking some eggs, but even so with the benefit of hindsight we should have anticipated better the immediate impact that the change was going to have on you and your clients. Also the middle of Pay and File was not the best time to embark on such change, but as you are well aware it is difficult to find a time in the tax calendar which is a good time to make a major change.

I appreciate the frustrations you must have experienced at times during the change process. It is always a matter of concern and regret for us when we inconvenience you. I hope for the most part that the change has settled down and that service is coming back to normal. There are still some problems in contacting PAYE offices, more so in some Regions than in others. We are doing our best to resolve these but I suspect unfortunately that it may take until well into 2005 when we introduce an entirely new computer system for PAYE before the problems go away entirely.

I am not going through the full rationale for Restructuring, nor am I going to describe the new Regional structure in any detail. Many of you have heard or read about this already - it has been well covered in an explanatory leaflet, on our web site, and in considerable detail in Tax Briefing. However for the next few minutes I want to focus on some of the planned outcomes of the new structure which I expect may be of some particular interest to you.

Risk
There is one four lettered word that is going to encapsulate much of our compliance approach in the future - RISK.

One of our big considerations in designing the Revenue of the future, was to create a structure and an administration which will enable us identify the major risk areas to tax compliance, both existing and emerging and to be in a position to respond effectively to those risks. That consideration, more than any other, informed our decision on what types of Divisions and Districts we would create.

The design of the new risk focussed Revenue features -
A Large Cases Division responsible for our biggest customers, corporate and individual.
An Investigation and Prosecutions Division.
High Risk Districts in some Regions, with a remit similar to LCD for the next largest tranche of cases.
Special Compliance Districts which will have a particular role in identifying and tackling Risk in each Region,
General Districts which will take a whole case approach to compliance for every tax and duty.
RLS (Revenue Law Services) which apart from assisting in the legislation and interpretation process will have a major role in "minding the tax", identifying potential abuses and leakages for every tax,

And of course my own Division which will continue to manage payment compliance on a graduated risk basis, with case size, compliance history, level of debt and habitual abuser status (in the corporate sense) all among the risk drivers.

And finally we are deploying innovative new technology to assist in Risk analysis at individual case level.

Risk Analysis System
First lets look at the technology side and audit selection. Up until now audit selection has either been event driven, e.g. by a large VAT repayment claim - recently often programme driven in the context of the BNR, offshore asset programmes etc. - or as a result of screening of accounts and returns by an experienced auditor. Indeed this system has served us well... in 2002 for example we recovered €262million from 16,000 regular audits.

But the system has its limitationss. For example, not all information in relation to the case is readily available when the case is being screened and there is a physical limit to the number of cases that can be screened each year.

Our new system, with ESKORT which is an analysis engine in use by tax authorities worldwide at its core, will enable us to combine and risk score cases using all available information. This will include for example:
The accounts menu information - the system will score certain features of the accounts for internal consistency and industry norms.
Other returns, e.g VAT and RCT , third party returns, ST21s etc. - the system will evaluate the consistency of returns with other available information
Compliance history - the history of timely compliance for both payments and returns will carry a risk weighting.
The system is about to commence. The first set of "selections" will reach the Regions shortly. The system will of course take time to bed down, and as is the experience in Revenue jurisdictions everywhere, the system involves a continuous learning curve, recognizing what rules best identify cases engaged in tax evasion, and what relative weighting should be given to different rules. Also remember, the system is an aid to audit selection...... cases will still be selected by our Audit managers based on potential risk as highlighted by the IT system but we are not now, and never will, delegate the actual selection to the computer.

There is one other point on which I want to be very clear. We have decided that Risk Analysis will be applied to particular categories of data only when the same level of information is captured from ROS and paper filers, and to this end we are investing in data capture of accounts information and a range of 3rd party information. We guarantee absolutely that ROS filers will be no more subject to risk analysis or audit than anyone else.
Our people
All of our new compliance Districts and teams are staffed with officials from a variety of backgrounds, some from the inland revenue taxes, some from Customs and Excise, some from a single taxhead background, and some entirely new to compliance work.

The nature or the work, and of the risk, has meant that large numbers of our most experienced staff have been assigned to Large Cases and Investigation and Prosecutions Divisions. We clearly have a huge task facing us, in training staff already skilled in audit for additional taxes or duties, in training some staff almost from first principles, and all the while, evolving improved and more effective ways of doing this work. This will be expensive, and will mean that it will take some time - not too long hopefully - before the new structure reaches its full potential.
But there are short term plusses as well. The new teams have broader Revenue experience - both the teams are composed of staff from customs and taxes backgrounds, and because we have eliminated historic demarcations between different grades. This means that from the outset we will be better than we ever were before at combining knowledge and skills in tackling risk and evasion. We are I think already beginning to see some results from this integrated focus on profits, sales, payroll and vehicle taxes and customs, CAP and excise activities. And we have commence programmes of CAT audits, to be followed very soon by a new programme for Stamp duty audit.

LCD
Our Large Customer Division is one of our key Divisions in the new Revenue. It focuses on the biggest risk.... i.e. on the biggest taxpayers, both corporate and individuals, in this economy. Even a quick look at our resourcing of this Division, with all units headed by a manager at Principal level, and including two units focusing exclusively on anti-avoidance, signifies the level of investment we are making in this Division, and the seriousness with which we are tackling the task. The Division is staffed with personnel experienced in both tax and customs and excise, and is being further boosted through the introduction of five accountants working full time in the Division, with more to be recruited shortly. We are investing heavily in training and re-training in tax, customs, accountancy and other specialised areas and in computer auditing and forensic auditing. We will need to continue this investment for some years to reach the full level of capability we feel is required to be fully effective in achieving the kind of impact we would like to make on the compliance behaviour of large cases.
LCD's approach is to focus on key criteria such as
Becoming more informed and developing new relationships with their customers
Profiling large companies and high worth individuals to map how they operate both domestically and globally
Ensuring that all large taxpayers are subject to some form of audit in the next 5 years.
Capturing the essence of what constitutes good compliance and encouraging the larger clients to live by those rules and to move away from contrived tax avoidance schemes.
Moving towards more real time audits, e.g. while acquisitions or mergers are taking place. That would allow tax-planning decisions to be influenced at the time they are being shaped.
Many of you are aware that the Division has embarked on a series of introductory meetings with the senior management of the country's largest companies. This is an exercise to introduce companies to LCD, and to Revenue's expectations as to the appropriate compliance culture in these companies. In those meetings they are proposing to the companies that they should consider engaging with us in agreeing Frameworks of Compliance under which the companies would undertake to observe defined standards of compliance in all tax and customs areas and in return for which Revenue would offer higher levels of service and support and less intrusive interventions with the associated lower compliance costs. They are asking all large taxpayers to begin and to institutionalise a process or rolling self-audit and to make voluntary disclosures where they become aware of unacceptable compliance practices. They are offering an open door to businesses who complain about unfair tax based competitive advantage in their sectors, and they will make use of this kind of business intelligence to adjust their industry and company risk profiles.

Seán Moriarty, who is the head of LCD, has pointed out on several occasions, including recently in a presentation to TALC, that these direct contacts with companies are not intended in any way to change the critically important Revenue / Practitioner relationship. Indeed we are clear that building an ongoing dialogue with tax advisors is a vital part of doing business. The Division has already had a series of bi-lateral discussions with the major accountancy/tax firms to deal with issues of concern to tax advisors arising from the interaction between LCD, the advisors and their clients. They are however, insisting that the parallel line of communication to business is a critically important part of Revenue strategy, but clearly this line is not intended to undermine the role of the advisor.

The Division is offering support with interpretation and have recently signalled that they are exploring the possibility of introducing a rulings system. This, I am sure is something which you will encourage, and it is something which I hope can be delivered in the not too distant future.
Other Divisions
Finally, in relation to restructuring, just a quick look at some of the other new functions. I am not going to comment on Investigations and Prosecutions Division - its title probably speaks for itself.

For now in relation to the Revenue Law Service Divisions, suffice it to say that its minding of the tax function will involve for example co-ordination of activity across the Regions in investigating, through audit if there is evidence of illegitimate shifting of income taxable at 42% to gains or gifts taxed at 20%. While there are many complex factors at work, comparisons of the yields from Schedule. D income tax and from a very healthy Capital Gains Tax, and analysis of the sources of the gains, points at least to legitimate questions for which we must find answers.

The Special Compliance Districts in each Region are intended to facilitate looking at Risk in new ways....often for example in real time inquiry, investigation and audit. Among their many activities they will focus on major infrastructural projects in the Region, looking perhaps at all of the contractors in a major road building project. Or in a major building project ensuring that all the bases are covered, from RCT, PAYE , PRSI, and CT right through to the payment of VAT when the development is eventually sold on and extending subsequently to the registration of new businesses or landlords occupying the development.

ROS
It used to be that no Revenue presentation appeared complete without a reference to the introduction of Self Assessment. These days, that never to be omitted accolade goes to ROS, the Revenue On-line service. So for the next two or three minutes I am going to observe that convention and pay homage to our greatest state of the art contribution to
e-Government, customer self service, and all round efficiency.

Being very serious, ROS is all of those things, and it really came of age round-about 21 November last year, with your adoption of the system in very large numbers for Pay and File. As you probably know 40% of all returns filed, 115,000 returns in total, were filed though ROS. This was a very significant vote of confidence in ROS by you. I hope overall you found the experience satisfactory, and that you will continue to use the facility in the future, and that those of you who have not yet made the switch will do so in the coming filing season..............better again..........no time like the present.

I acknowledge that there were some transitional problems on the key filing date last year i.e. 21 November. For part of that day, the response time deteriorated beyond a point that was acceptable. We have, since then, spent a lot of time and resources in identifying what went wrong, and ensuring that the same problems will not re-emerge in 2004, or at other busy periods.

I am confident that what happened last year was a once off occurrence. While it was disappointing that the system performed below par, Revenue assurances, confirmed in a press release, to the effect that no customer would be disadvantaged through being unable to file, mitigated the worst effects of the event.

Outside of the Form 11 and VRT the uptake has been slow. If you are discussing PAYE or VAT with your clients give ROS a plug...........where you file these returns for clients and indeed when you are filing your own returns don't forget the ROS option.

If you need help, either in using the system, or in signing up, the best approach is through your local ROS liaison officer, or by contacting the ROS Helpdesk directly. You will find contact details for the ROS liaison officers on the Revenue web site.

Speaking to practitioners and to other Revenue customers who use the system the reaction is for the most part extremely positive. Revenue has invested heavily in this system and we see ROS as a win / win solution for both practitioners, their clients and for Revenue. It cuts down on costs for all of us, in paper, postage, processing, errors etc. It gives certainty, on-line calculation and rapid turnaround of assessments. It gives certainty as regards payment dates and it has very useful add-on services, such as the availability of taxpayer statements for your clients. If you have not tried it..........please do give it a chance and once you adapt to it I would be amazed if you decide to revert to the old way of doing things.
Here is a quick to-do list for ROS customers or prospective customers
Register early
If you need help get it NOW, don't wait until September
Ensure your client list with Revenue is up to date
Set up payment authorisation and instructions well in advance. We will not take the money regardless of when you authorise it until 18 November unless you specifically instruct otherwise

And one last thing on ROS..........we are again offering an incentive in the form of a due date extension for Pay and File 2004 as was agreed at TALC. This year the extension will be until 18 November...............compared with 31 October for paper filers.
As was the case last year, to avail of the extension, you must pay AND file using ROS. The extension of course comes at a significant cash-flow and interest value cost to the exchequer, but I believe it is appropriate where we can to give some acknowledgement to those who use the system.

Conclusion
Finally I would like to focus on our obligations to one another.
I referred earlier to my belief that we share responsibility for tax compliance. You have obligations - professional, legal and moral - to ensure that the accounts and returns are accurate and specifically that you never allow yourselves to become a party to deliberate tax evasion.

We have a shared obligation to secure proper compliance and to ensure that your clients, my customers pay what they owe, no less, no more.

I acknowledge that you cannot take responsibility for every incident of non-compliance by your clients, and I am very conscious of the major part you play in ensuring full and timely compliance by your clients. I would like to think that you see it as part of your role, that where you know that taxes are not being paid in respect of returns that you file, or where you see that PAYE and VAT is not being paid or that the amounts of direct debits are inadequate, to advise your client of the potential costs and consequences of non-compliance.

Part of your service in securing proper compliance is through professional advice and professional tax planning. This, as Revenue Chairman, Frank Daly said to you at this conference last year, is an important service to taxpayers, in an environment of complex tax legislation. We will continue to support you in this through our programme of Statements of Practice, Codes of Practice, Tax briefing etc.

Part of our obligations to you and your compliant clients is in delivering a level playing pitch. We owe it to you, and the compliant tax community to make the necessary interventions at the earliest stage when payment or returns are not submitted, and to follow up with sheriff, solicitor, attachment or court action as necessary and through a well targeted and effective audit programme.
We will continue to discourage and combat aggressive tax avoidance in whatever way is required without apology.

We have made big strides in improving compliance over the last number of years, through re-allocation of resources and improvements in our IT capabilities. Restructuring gives us a better platform now to make further progress. We recognise that there is more to do, we will never say that we are 100% satisfied with our efforts. We will continue to develop our strategies and to improve our IT and will constantly look to take the next leap.

To quote Josh Billings - "We will not stop to celebrate minor milestones but will push onto the ultimate goal" which in this case is achieving the very highest levels of compliance possible.

Thank You

Back to Top

Print this page