South West Business News. South West Business News Winter old mill: listening, analysing, advising
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1 South West Business News South West Business News Winter 2012 old mill: listening, analysing, advising
2 2 Chris Bowles, Head of Business Services Old Mill update Welcome to the Winter 2012/13 edition of the South West Business News. Apparently we are out of double dip recession and the economy is growing strongly with rising employment. Or is this largely driven by one off factors such as the Olympics? The jury still seems to be out. However, what is certain is that there are still many issues facing businesses striving to grow and in this edition of South West Business News we cover a wide variety of topical issues. We are sure you will find many articles of relevance and interest. When the opportunity for 14,000 sq feet of refurbished former HMRC offices right in the centre of town came up it was too good an opportunity to miss. The open plan offices are modern, bright and airy with wonderful views. We hope many of you will be able to attend events to see these offices in the coming months. In the meantime the building of the new Wells office moves steadily forward. You may have noticed that the weather has been a mite unkind this past summer! But we are still on target to move in next March. We look forward to working with you over the coming months. The biggest news this quarter was our early November move to our new offices in Maltravers House in Yeovil. Although we had been very happy with our Goldcroft offices of the past 14 years or so, our staff numbers had increased to such an extent that space was very much at a premium. Maltravers House the new home of Old Mill, Yeovil.
3 3 Isobel Savage, Senior Tax Manager Research & Development (R&D) tax credits R&D tax credits are nothing new, they were brought in years ago to encourage investment in innovation. The principle is reasonable if it costs less (via tax relief) to invest in new products/materials or improvements to existing ones, businesses are more likely to do so. This relief has become more and more valuable over the last few years. In fact for 10k of qualifying expenditure incurred after 1 April this year for an SME paying tax at 24%, the total tax relief can be as high as 5,400! It effectively only costs the business 4,600. The biggest barrier to claiming this relief that we have found appears to be people s perception as to what qualifies as R&D. Old Mill have enjoyed being involved with quite a significant number of cases where we have made some interesting and cash saving claims for our businesses, in situations where the client had been fairly sceptical. Before we give some real life examples, I will set out the fundamentals of the relief: 1. If your business is liable to corporation tax, then it may be eligible for Research and Development tax credits. 2. Your Company must be spending time and money on projects seeking to attain an advance in a field of science or technology. You need to be able to identify a technological or scientific uncertainty i.e. a problem which you are working to overcome. You might not even be working on an entirely new product but rather an appreciable improvement to an existing product, material, process or service which is relevant to your business. 3. HMRC expect you to be able to say why a competent professional in the field couldn t readily overcome the uncertainty. In English, this means we need to be able to say what else is on the market, what knowledge is publically available and why this wasn t standard work that would be expected in any business. Although there are other rules to consider, including when qualifying R&D starts and when it ends, if you think your company may have undertaken some qualifying work then don t hesitate to ask your accountant whether R&D tax credits might be available to you. Here are some real life examples of R&D tax credit relief we have worked on with our clients and potential future claims: 1. Using an anaerobic digester in a food business where the waste input material was out of the ordinary. 2. The development of new potential uses for the waste product of a manufacturing plant. 3. Overcoming the technical problems of replacing one type of paper with another in a product which caused problems with the manufacturing process and other materials used and the adhesive. 4. Overcoming issues where the reduced fat content required in a food product had a negative effect on its taste, texture and shelf-life.
4 4 Accounting from the front For far too many small businesses their accountant is seen as a cost; a bit like a dentist someone who inflicts pain and then charges for it. Too many accountants spend far too much time on the reporting and compliance side of your business, telling you what has happened and never getting around to the important matter of how they can help you to move your business and your personal financial situation forward. At Old Mill we believe your accountant should be helping you by leading from the front. We need to understand you and your business so can we provide you with relevant and active suggestions about things that can help you improve and to grow your business and increase your own financial security. Fine words but what is the substance how can your accountant really help you? Obviously by helping you keep your financial affairs in order so you only pay the tax you need. This leaves more to re-invest and increase your profits to serve you and your business further but that is just the starting point. We here set out typical areas in which we think we can do far more for you.
5 5 Strategic Planning for your business Where are you going, how are you going to get there? Old Mill can help you succeed with planning and projections to help mitigate tax liabilities and assist you in making your business better. Failing to plan is planning to fail. Business structure There are a number of options including Limited Company, Partnership, Sole Trader, Limited Liability Partnership or whether a pension scheme can help with property ownership we can help you decide the right structure for your business. Remuneration strategies There are many ways of drawing money from your business so we check that you are getting the most tax efficient solution for you and your business. Projections and year end We look into the future for your business with tax liability projections which are particularly important with pre year end planning. R&D tax credits The government backed tax incentive. Too many businesses get put off by the R for Research and think this is not for them if you focus on the D for Development it becomes a lot clearer that this could be an major benefit for many more of you. VAT advice There is a lot more that can be done with VAT than many businesses realise and we have a VAT consultancy service which can aid significantly. International Trade Whether exporting for the first time or looking at importing we have experts in International Trade who can help guide you. Funding Do you want to make an application for funding from banks or other sources? It is increasingly important to get your application right first time Old Mill have a specialist banking consultancy team. Succession issues Do you need help with succession either passing the business down within your family or maybe to your senior management? Grooming your business for sale Will you want to sell your company at some point? There are many ways of increasing its value but the longer time we have to plan with you the more we can do to increase its value five years is often recommended. How much is your business worth? We can provide guide values for your company which will help you understand what wealth management actions you might need to undertake in the future. We can advise on steps you could put in place to improve the value of your businesses going forward. Personal Strategic Planning Where are you going yourself? What is your plan? How will you ensure your longer term financial needs are catered for? We can help you plan for financial security for you and your family. Pensions Do you have the right pensions in place could a SIPP or SSAS help you into tax efficient property ownership? We have a dedicated Pensions Consultancy to help you. On top of all this Old Mill can help you ensure timeliness in getting things done and provide the reassurance that your matters are being dealt with in a professional manner. Accounting from the front may sound too good to be true but should you and your business be accepting anything less?
6 6 Judith Hemborough, Outsourcing Real Time Information (RTI) Real Time Information is the biggest change to PAYE taxation since its inception in HMRC recognised that working patterns have changed and that accurate records were needed for the tie in with the Universal Credit benefit system due to be introduced in October The structure of PAYE remains the same but the way of reporting will change. It will affect all employers and HMRC will be writing shortly with details of the preparation needed for implementation. The introduction of RTI will take place for most employers from April 2013, with all in the scheme by October Currently there is a pilot scheme running and employers can volunteer to join RTI early. The key change is that instead of making an annual return via P35 Employers Annual Return, each time an employee is paid, either before or on the day of payment, a return is made online, this is known as Full Payment Submission (FPS). All employees are included, and P35(A) and P38(S) forms will cease. Therefore students/ workers/casual/ lower paid (under Lower Earnings Limit) employees will need to be included in the FPS. Your Old Mill contact will be pleased to talk to any clients who may have initial concerns about this change.
7 7 Steve Woodham, Pensions Manager Lending to your own business Most businesses need investment to help them grow, or to develop new products and services, however securing finance remains an obstacle. Companies invariably look to external sources which can include private individuals, venture capitalists, business angels and banks. Many directors are finding that lending criteria has become tougher as aversion to risk continues to dominate lending decisions. Few are aware of a source of funding considerably closer to home; namely a director s own pension assets. Many business owners are using their pension funds as an alternative to help secure loans to their business in light of the difficulties. UK pension funds are permitted to lend money to its sponsoring company, the type of pension vehicle that can be used to lend money to a company are Investment Regulated Pension Schemes which are commonly known as Small Self-Administered Scheme (SSAS). The ability of the SSAS to lend to a sponsoring employer at commercial rates has provided a lifeline to business owners whose bank will not entertain further lending in the current climate. A SSAS is a Registered Pension Scheme with HMRC and is able to provide a unique alternative for companies seeking funding. This pension vehicle can also be used to receive transfers from the director s existing pension assets which may be held in a pension that is not permitted to make loans, once the pension has been transferred to the SSAS it can subsequently be used to inject cash into the business. The SSAS will also enjoy considerable tax benefits including corporate tax relief on contributions paid by the company, income tax relief on contributions paid by the member and investment growth free from income tax and Capital Gains Tax. SSAS rules allow up to 50% of the net assets of the pension fund to be lent to the member s business which must be secured and the SSAS Trustees would charge the business a commercial rate of interest. This can be attractive as rather than paying interest to the bank the interest is paid into the members pension fund and will grow tax free.
8 8 We hold many tasting session when we introduce new products into our range, comments Brian. We have very willing family and friends who trial our products and hold regular tasting evenings, videoing them for feedback, as well as external tastings, making sure the right products are created ready for market. Client Profile Yumble With a passion for food and experimenting with recipes, Brian Noctor and his wife Isobel diversified from careers in journalism and professional services to create Yumble. Based in Somerset they create sweet and savoury crumbles with local and seasonal ingredients. Brian comments I worked in London for 15 years in banking and then moved to the South West where I managed a local law firm, but ultimately I wanted to run and manage my own business. Isobel and I came up with the idea of Yumble and spent six months developing a suitable range of products whilst still keeping my day job going. In August 2011 we started trading and were delighted that by Christmas, shops were approaching us for stock. Brian and Isobel visit between one and two farmers markets per week ranging through Frome, Bath, Wells, Bradford-on-Avon, Devizes, Salisbury and Yeovil. They also sell their products through 15 community shops in Somerset, Wiltshire and Dorset as well as local supermarket Budgens in Bradford-on- Avon, Woody s Farm Shop near Bath, Frome Whole Foods and many others. Sourcing locally is key to their business and all their dairy and meat is from the local area. They even use a Frome based graphic designer, website designer and photographer! Use of social media has been key to their business development and with their website nearly ready for online sales, this will be a crucial medium for promoting their business. Brian comments with Isobel s background in media we know advertising and word of mouth is fundamental to spreading the word about our products, encouraging purchases via our stockists and eventually online. We have done some successful Facebook advertising which has worked really well using market segmentation and this has generated some good feedback for us. We are definitely looking forward to the future and establishing our product as the crumble of choice! For more information on any of Yumble s products visit or call Brian on Follow them on Like them on Facebook: Yumble, Love Crumble. We have also developed a relationship with a veg box scheme in the Thames Valley which supplies our products into London and we were recently trialed in a national garden centre chain, comments Brian. Ideally we want to build up the business locally in the short term to create a profitable business with a long term view of supplying high end supermarkets and creating a profile nationally via our website with online sales. We are looking forward to working with Chris Bowles at Old Mill, and with his support really pushing our business forward. This year Yumble won a Gold medal in the Taste of the West awards for their Le Crumble, Brian and Isobel understand the importance of creating top quality products using quality ingredients to produce flavours and textures that complement each other in both their savoury and sweet ranges.
9 Matt Haines, Assistant Manager, Business Services Small Business Healthcheck When tax planning is mentioned, the first thing which comes to mind can often be complex business structures involving foreign companies, but for smaller concerns (and indeed some larger), a lot of simple things can be done in order to maximise tax relief for both you and your business. Below are a couple of areas we have been finding relevant to owner managed businesses. Mobile phones By ensuring that employees (including directors) mobile phone contracts are taken out in a company name, the full cost of both the service charge and calls/ data usage is tax deductible and outside of the benefit in kind regime. Smartphones are also covered by this exemption. Tax-efficient salary Directors of owner-managed companies can mitigate both national insurance and income tax by paying themselves a salary below the Lower Earnings Limit and the Earnings Threshold. An amount of 7,488 for the current tax year to 5 April 2013 will achieve a qualifying year towards the individual s state pension and, assuming the director has no other income, will not create a tax or national insurance liability. Assuming available, company profit reserves can be distributed via dividends in order to top up income; this avoids national insurance altogether and income tax up to the individual s basic rate band ( 34,370 in 2012/13). Annual parties The cost of staff parties, when available to all employees, is an allowable business expense up to an annual limit of 150 per person. When considering the number of people attending the event, HMRC allow both employees and members of their household (also attending) to be taken into account. Remember that this amount is not an allowance to deduct from the total cost of parties in the year so if the cost of one party exceeds the 150 per head limit the full amount is disallowable for tax. It is possible to consider several staff functions throughout the year and apply the exemption appropriately to ensure it is not breached and the maximum relief is achieved. The above should always be discussed with your business adviser before implementing to ensure that the wider impact on both your business and personal affairs is considered. 9
10 10 Gavin Jones, Certified Financial Planner What will auto-enrolment really mean for your company? The beginning of October was the start of auto-enrolment, the biggest change to retirement savings in this country since Lloyd George introduced the Basic State Pension in You may have read about this in the media with commentary torn between the need for retirement savings in the future and the damaging effect of such a large burden placed on employers in the worst economic climate many of us have experienced. We have certainly included several articles in this publication in the last few years talking about the changes, but as we approach the deadline for some of our clients what are the things you really need to know? Most companies are unprepared Over the next 6 years, 1.3 million employers will become subject to auto-enrolment with the obligation to set up pensions for their staff and make contributions to a pension scheme for their employees. Of these, 1.2 million have fewer than 250 staff and three-quarters of those are with 4 or fewer employees. Most of these companies are unprepared, unclear about what to do and unaware of the new auto-enrolment duties placed upon them, according to research by the Association of Consulting Actuaries (ACA). A lot of our clients haven t really thought about the changes with smaller companies not needing to comply until 2018 at the latest. Others will now not have that long until the deadline looms and there will be financial penalties for those that have not implemented the necessary changes in time. Which pension scheme? It is thought that a million employers do not have a pension scheme at all but even if you do it may not be suitable at all and need changing, or at least need a few tweaks to comply. There are many with no scheme at all and there are a number of choices to make. It will be possible to set up a company specific scheme but there are also some larger schemes set up, and you may have heard of the National Employer Savings Trust (NEST). There are pros and cons for each and these need to be considered in your individual circumstances and requirements. Where is the money coming from? If your staff choose to join a scheme it will be mandatory to make contributions on their behalf. This will start as 1% of their total earnings, but will rise to 3% after a couple of years. The ACA state that only 28% have budgeted to date for the cost of auto-enrolling their employees into a workplace pension scheme. Those that have budgeted expect employee opt-out rates from schemes ranging in the main between 11-35%, with the highest opt-out rates in the smallest firms. We know that in companies where there is an existing scheme the number of staff that don t join is high, even when there is a generous employer contribution. So we would expect some not to join but there is already advertising highlighting the changes and the importance of saving so you should at least consider the costs if all of your staff choose to join. Will my payroll software cope? We don t know. It is perhaps an important lesson that we have met with many providers of payroll software, and pension scheme providers who know what they want to offer, but don t yet have systems that they can demonstrate. There is no doubt for many this burden is unwelcome, but the longer you leave yourself to implement the changes in your scheme hopefully the less impact it will have on your business as a whole. We have to have faith that they will provide working systems on time but as we have said before there will be financial penalties for not enrolling staff on time at the outset or when new staff join.
11 11 The Pensions Regulator has made it clear that they will not accept any excuses and it is essential to have a foolproof process in place to make sure this happens. This will often be difficult with information coming from several different sources your payroll, and one or possibly more pension schemes as well. How complicated is it? If your work force is salaried and reasonably stable the new regulations should not be too onerous. However, if you employ casual labour, seasonal staff or have employees with fluctuating wages at first glance it looks like complying will be complicated. In these circumstances it may be necessary to assess your workforce once a month to ensure that any staff that become eligible are auto-enrolled within the permitted timescales. How much do you care? A contentious point but the Government is ultimately placing some responsibility for employee welfare firmly at their employer s feet. Realistically when times are tight many of you will merely want to do enough and no more. But even for those that do not opt out immediately, the rate of savings needed to provide an adequate lifestyle will not be provided by the minimum savings levels prescribed. Of course you may not believe this is your responsibility but if you are looking to attract, motivate and retain the right staff then we are able to advise workforces as a group or individual basis to educate and encourage good savings behaviour to provide enough in retirement. It s already started You are already subject to this legislation. It is already law that you cannot be seen to discourage people from joining the pension and there are penalties for anyone caught doing so. The implications of this are wider than originally thought and will even apply to people you are interviewing for roles and not just your staff! In summary At Old Mill we understand why the new legislation is necessary, but the rules seem complex especially for smaller firms and impose more work on firms when many are working flat out to keep their heads above water. But there is not a choice and we are here to help you meet your obligations. If you have any questions or would like to talk to us about the new rules or our services speak to your usual Old Mill contact. Auto-enrolment key facts 1. Know when you need to act find out when the changes start for you (your staging date). 2. Start the planning process: Know which staff this change applies to Review your pension scheme if you have one already to check it is suitable Set up or join a new pension scheme if you don t have one 3. Decide who is responsible for communicating and implementing the changes: The employer duties will typically effect Payroll, Finance, HR, IT Put a plan in place to ensure you comply in time 4. Communicate the changes to your staff. How Old Mill can help 1. With our dual role in Accounting and Pensions we are ideally placed to oversee the changes your company needs to make and ensure you comply with the regulations initially and on an ongoing basis. 2. Ask us for an impact report which sets out the duties and dates for your company. 3. Review your existing pension scheme 4. Set up a new pension scheme 5. Outsourced payroll services
12 12 Client Profile AB the ideas agency In a quiet corner of Exeter City centre is a place that understands the power of ideas. AB is a creative communications agency operating in the heart of Exeter but competing on a national and international scale with clients such as Heineken (UK), The Met Office and the BBC World Service as well as local businesses including South West Water, EMCAS and Rick Stein. Ed comments The business has grown over the past thirty years from just two graphic designers to a team of 30, including designers, developers, strategists and film makers, a team which myself and the other two partners, Marcus Bennett and Henry Sanford are very proud of. AB offers a range of creative services from design to digital, consultancy to film but at the heart of everything they do is the idea. AB works with its clients to help distil their ideas into concise and clear messages by applying common sense and sound commercial thinking in everything they do. A service they believe offers the best value for money to their clients and is a fundamental factor in their success in recent years. Other factors that have contributed to AB s growth has been the increase in new business, its lack of dependency on public sector clients and their employment of quality staff, a lot of our staff have relocated from London, comments Ed and they can offer the latest in commercial thinking. They deal directly with their client accounts which not only means speedy delivery but this also gives excellent client service, avoiding any mistakes that can occur through Chinese whispers. In recent years AB has found the local business environment becoming a lot more competitive and with existing clients spending less the need for new business is critical. AB works closely with James Fowler and Isobel Savage at Old Mill and has valued having all their accountancy needs under one roof. Ed comments Old Mill initially helped us with restructuring our business to help reduce the amount of any unnecessary tax, making the whole process very easy whilst explaining all the benefits, but we now work with them to make sure we can keep moving our business forward. Ed s vision for the future is one of optimism and he remains confident that with continued hard work, innovative and creative ideas and continuing to deliver great customer service that AB will continue to grow to be one of the leading creative businesses in the region. For more information please contact the AB team by calling , ing info@ab-uk.com or by visiting Follow them on
13 13 Jon Burt, Business Services Manager, Melksham Invoice discounting Businesses should ensure that their debt collection procedures are robust, so that they are able to manage their cash resources effectively. Invoice discounting is an alternative method of finance. It allows a business to draw money against its sales ledger shortly after the invoices have been issued to customers, often within 24 hours. The drawdown is typically 80% of the invoice value. The remaining 20% is available once the invoice has been settled by the customer. This arrangement aids cash flow as well as obtaining valuable support and credit insurance services from the invoice discounter. Invoice discounting and debt factoring are collectively known as invoice finance. However they are separate products. With invoice discounting your business retains control of its sales ledger. You are not required to inform your customers that you are using invoice discounting as you still collect the debts and deal with credit control. This is different to a debt factoring arrangement where you sell your sales invoices to a third party, who then takes on the debt collection and sales ledger management for you. There are a number of invoice discount providers including major banks, financial institutions and independent providers. These organisations will all have their own criteria for assessing whether invoice discounting is appropriate for your business. Generally your business needs to be selling products or services on credit terms to other businesses. It isn t available to retailers or cash traders. Your business needs to have a proven track record and a turnover often in excess of 250,000. The invoice discounter will want to review the businesses finances and study your business plan. As with all types of financing, there is a cost attached. Fees for invoice discounting are lower than for factoring because you will manage and collect the invoices yourself. Invoice discounting fees typically range from 0.2% 0.5% of turnover. Alternatively you may be charged an agreed fixed fee and interest on the net sum advanced, calculated on a daily basis. It is advisable to look at a number of different invoice discounters before you enter into an agreement. Compare the charging structure, the draw down facility and the cancellation notice period. Notice periods can vary from between 28 days to a year. Invoice discounting is one method of financing available in the market. As with all business decisions it is essential that you assess whether it is an appropriate solution to help you take your business forward.
14 14 Duncan Parkes, Director and Chartered Financial Planner of the year 2012 Is your financial adviser ready for life in 2013? By now many of you will have heard about some changes that are taking place in the financial services sector in 2013, but what do they all mean? The Financial Services Authority has, for some time, been working on the Retail Distribution Review which put simply, will see the implementation of three key changes to the way you receive financial advice. What is changing? n Clearer charges instead of being paid by commission through a product, advisers will have to agree their fees with you in advance of any advice being given. n Clearer services your adviser must disclose whether they are able to advise on all available options or only specific areas n More professional advice your adviser will have to meet higher standards of qualification, ensure their knowledge is maintained and sign up to a code of ethics requiring them to treat you fairly. How do you know if your adviser has made the necessary changes? I have listed below some questions that you may like to ask your adviser to ensure they continue to meet their ongoing obligations. 1) What experience do you have as an adviser? Find out how long the adviser has been in practice and the number and types of companies they have been associated with. Check that they also have experience in dealing with clients of a similar financial make up to yourself. 2) What are your qualifications as an adviser? Your adviser should by now have reached, as a minimum, QCA Level 4 which in the UK usually means having a Diploma in Financial Planning from either the Personal Finance Society or Institute of Financial Services. If your adviser holds either Chartered or Certified status this sets them out from the crowd as going that extra mile to improve their technical knowledge. It is also worth checking what steps your adviser takes to stay up to date with changes and developments in the financial planning field. 3) What services do you offer? Not all advisers will be authorised to advise on all areas of financial planning. Some may be restricted in their choice of products and/or providers and some may be restricted in the scope of their advice. There are, for example, specific qualifications required to advise on some types of pension transfers and long term care. It is therefore vital that you check your adviser has the ability to advise on the areas you require advice on. 4) How much do you typically charge? Your adviser should by now have a clearly defined fee structure which explains how they intend to charge clients from January Ask to see a copy. 5) How will I pay for your services? Your adviser s fee structure document should include an explanation as to the options available to pay for their services. These are generally by way of a direct fee or via a payment from the respective investment or pension. Remember this should be your choice and your adviser should be able to accommodate your wishes. 6) Can I have a copy of your Code of Ethics? Each adviser should have a Code of Ethics which details their responsibilities to you the client. Ask to see a copy. Any adviser who is fully prepared for the forthcoming changes should be able to answer these questions with ease and have documentation to back up their comments. Old Mill has been developing its service proposition over the last four years and already meets all of the requirements to remain at the forefront of financial planning in If your existing adviser cannot answer the above or you would like to discuss any aspect of this article please contact us.
15 15
16 Recruitment At Old Mill we are always interested in talking to people who are looking for a career in Accountancy or Financial Planning. Our business is our people. We have a high commitment to training our staff for professional qualifications in both disciplines. If you know of someone looking to develop their career, maybe a graduate or somebody who already has some level of qualification or experience and wants to develop further, it is well worth them contacting us. While our website contains details of our current vacancies, we are always on the lookout for talent. CVs should be sent to careers@oldmillgroup.co.uk with a covering note. Contact Old Mill Head of Business Services Chris Bowles Tel: chris.bowles@oldmillgroup.co.uk Simon Hartley, Dorchester The Old Rectory, South Walks Road Dorchester, Dorset DT1 1DT Tel: Fax: simon.hartley@oldmillgroup.co.uk James Fowler, Exeter Leeward House, Fitzroy Road, Exeter Business Park, Exeter, Devon EX1 3LJ Tel: Fax: james.fowler@oldmillgroup.co.uk Jon Burt, Melksham 4 Challeymead Business Park, Melksham, Wiltshire SN12 8BU Tel: Fax: jon.burt@oldmillgroup.co.uk Richard Reynolds, Shepton Mallet The Old Mill, Park Road, Shepton Mallet, Somerset BA4 5BS Tel: Fax: richard.reynolds@oldmillgroup.co.uk Craig Howes, Yeovil Maltravers House, Petters Way, Yeovil, Somerset, BA20 1SH Tel: Fax: craig.howes@oldmillgroup.co.uk Find us on Facebook, LinkedIn and Twitter The content of this newsletter is for general information only. It should not be relied on and action which could affect your business should not be taken without appropriate professional advice. Please contact your usual Old Mill contact or local Old Mill office.
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