Section 49 requires the personal consent of the DPPNI, or Director of the SFO before any prosecution is brought for the foreign revenue offence. Such a prosecution may raise complex issues around the public interest and the relationship of the United Kingdom with other countries necessitating this safeguard.
Part 3: Corporate offences of failure to prevent facilitation of tax evasion Offences: general and supplementary provision Section 49: Consent to prosecution under section 46