June 27, 2022
Sergey Atamas, managing partner of Kreston Ukraine, explains how Ukrainian accountants and auditors are dealing with the ramifications of the war. Read the full article here.
May 27, 2022
Accountants, business and financial advisers Kreston Reeves has strengthened its market-leading Restructuring team with the appointment of Carrie James.
A licensed insolvency practitioner, Carrie joined Kreston Reeves on 18 May from SKSi where she was the managing director and head of insolvency.
She brings to the firm an impressive track record of helping businesses solve problems that are too great to be resolved on their own. Much of her work has an international perspective, with strengths in the mining and natural resources sectors. Carrie also brings a proven track record in building and growing a business, founding SA Insolvency before merging with Benedict MacKenzie, now SKSi, and leading its expansion programme.
Carrie is the immediate past president of the Insolvency Practitioners Association and sits on its External Affairs and Membership Committee and its Management and Risk Committee.
Commenting on her appointment, Carrie said:
“Kreston Reeves is a firm I have long admired. It has a strong position in London and the South East yet with significant opportunity for growth. Importantly, the firm is principled with values that reflect my own. it is an exciting time to be joining the firm.”
Andrew Tate, Partner and Head of Restructuring and Transformation at Kreston Reeves said:
“This is a significant appointment for Kreston Reeves. Carrie is highly respected and with a strong presence in the insolvency community. We are thrilled by her decision to join Kreston Reeves and look forward to working alongside her.”
Luc works as a VAT expert at Kreston MDS in Beersel at Kreston VDN. He began his career as an inspector with the Belgian VAT Authorities. He provides VAT expertise and advice for the mid-market and SMEs. Luc has also worked within a large big 4 company as VAT director. He is specialised in EU VAT matters, cross border trade and real estate issues.
May 19, 2022
The harmonisation of rules for e-invoicing to close the VAT gap throughout the EU is one of the major issues within the EU becoming more digital. Directive 2014/55/EU regulates e-Invoicing in public procurement and aims to reduce trade barriers arising from different national legal requirements and technical standards for e-Invoicing. Each EU member state has developed its own implementation of the law, adapting the electronic invoicing model to its own legislative framework. Currently, electronic invoicing is mandatory in public procurement, while its use is developing in business-to-business transactions but is not yet widespread. The European Commission initiated a public consultation on the topic on 20 January 2022.
This e-invoicing Directive explicitly imposes criteria of authenticity of origin and content integrity, which must be obtained in three possible ways :
“Authenticity of the origin” means the assurance of the identity of the supplier or the issuer of the invoice and “Integrity of content” means that the required invoice content has not been altered.
A paper invoice must be archived in its original format and consequently e-Invoices must also be stored in their original format. If the original e-Invoice is an integrated machine format, such as Edifact, Tradacoms or XML it must be presented in a legible (human-readable) format. If software renders an integrated machine format as a legible e-Invoice in real-time during an audit it should be possible to check the information between the original electronic file and the readable document presented has not changed.
Each Member State can determine the period throughout which the storage of e-Invoices within its territory and are allowed to ask for translation into their official languages. But in contradiction, Member States may not impose a general requirement that invoices be translated. For audit purposes, all supporting documents must be stored with the invoice.
Where invoices are stored by electronic means Member States can require that the data guaranteeing the authenticity of the origin, the integrity of the content and legibility of the invoice is also stored by electronic means.
If an advanced electronic signature or EDI is used, the data guaranteeing the authenticity of origin and integrity of content, will be that associated with those particular technologies. If business controls are used, which creates a reliable audit trail between the invoice and the supply of goods or services, the data referred to is that of any supporting documents.
The European Commission’s “VAT in the Digital Age” initiative (and subject of a current public consultation) is looking at increasing the use of e-invoicing across the EU as well as looking to move towards a more harmonised set of requirements for e-invoicing and cross-border digital reporting. The policy options being considered include:
Hereafter, you can find a small overview of the implementation of the Directive in some EU member States and more specifically the e-invoicing rules for B2B transactions.
Of the European Member States, Italy is one of the most committed to innovation and the digital transformation of its public administration. It was one of the first EU countries to introduce electronic invoicing and is currently the only one that requires its use in both the public and private sectors. This is unusual in the European legal context, since current EU legislation only requires electronic invoicing in the B2G sector. Italy obtained approval from the European Parliament to extend this requirement to the private sector.
electronic invoices for B2B flows as from the 1st July 2024. France has recently announced that it will join Italy and will impose electronic invoicing. In France, the obligation to receive electronic invoices for B2B flows will come into force on 1 July 2024. The obligation to issue invoices will be imposed in successive steps.
In France, it’s estimated that 4 million businesses will need to get a new e-invoicing solution and be able to deal with receiving electronic invoicing.
France also organized a conference the 10th of February 2022 that has provided a forum for sharing implementation experience along with best practices in order to illustrate what the transition to e-invoicing entails and what businesses and government need to be successful in their endeavours.
The Belgian government has approved the Royal Decree of March 9 regarding the implementation of electronic invoicing with public administrations published in the Belgian Official Gazette on March 31, 2022.
The goal of the decree is to expand the obligation to issue electronic invoices to all the suppliers of public institutions of the country. The obligation will be expanded gradually based on the size of public contracts.
This obligation already exists for suppliers of the centralized entities of multiple regions (Brussels, Flanders, Wallonia). It will now be extended to the suppliers of public entities in all the regions
Belgium becomes another country in Europe like Italy and France that have decided to extend the mandatory use of the electronic invoice to public administration suppliers as mandated by European Directive 2014/55.
To ensure a sufficiently long transition period, companies would have until January 1, 2025 to adapt. Micro-enterprises would be exempted from the obligation.
Spain is passing legislation to start bringing in mandatory e-invoicing on a B2B basis. Full details are not yet known, and the timeline is going to be very much driven by when that legislation is passed. It’s anticipated to be very similar to France and start to come into play in 2024.
The Netherlands use is mandatory for public administrations and voluntary for B2B transactions. Private companies can use electronic invoices as long as their clients agree, and the invoice meets the legal requirements.
Poland is making progress in its project to massively introduce electronic invoicing between private companies. The use of B2B electronic invoicing is expected to be mandatory beginning in 2023.
Many other countries within the EU are studying the subject to impose electronic invoicing for B2B flows of goods and services.
In fact, electronic invoices also have a lot of benefits, such as :
As the EU is really moving into the digital age, every member state will, soon or later, impose the obligation to issue electronic invoices for B2B transactions. Every business is involved in such a process and should be aware of the advantages of moving to issue electronic invoices.
Also, the reliable audit trail, which we spoke about earlier, between the invoice and the supply of goods or services, will be very important in the near future. Supporting documents will be necessary in all cases. So, it’s recommendable to study this issue and implement this possibility for all businesses.
May 13, 2022
Kreston Global has today welcomed Kreston Macedonia, based in North Macedonia, to its global network.
Kreston Macedonia was founded earlier this year and was originally known as TPM Audit prior to joining the Kreston Global network. Led by founding partner Nenad Tortevski, it provides audit, tax, accounting, and valuation/forensics services to businesses operating in North Macedonia, from its Skopje office. They have launched a new website under their new name, which can be found here.
Liza Robbins, Chief Executive of Kreston Global, said:
“It is with great pleasure that I welcome Kreston Macedonia to the Kreston Global network. We are experiencing an unprecedented level of growth, a tribute to the exciting work carried out across the network in recent months and years. We will be working with our newest colleagues to build their links across the network as they explore new opportunities both at home and abroad.”
Nenad Tortevski, Founding Partner at Kreston Macedonia, said:
“Kreston Global are unique amongst global networks, in combining an established brand with an ethos of dynamism as well as market-leading services. They were a natural partner for us as we embark on this exciting venture.”
May 12, 2022
Environmental sustainability is essential for our earth, as climate change is ever-growing all businesses can adapt to support this. Accountants and auditors are in the best place to be able to give advice to clients on ESG and aid with sustainability frameworks in the future.
Liza Robbins, CEO Kreston Global comments here.
May 10, 2022
The UK firm which provides accountancy, business and financial advice has successfully achieved becoming officially carbon neutral.
Kreston Reeves partnered up with environmental experts, Anthesis to calculate and assess their carbon footprint and then chose to offset their carbon footprint by creating a Kreston Reeves forest through Ecologi. They arrange for trees to be planted by world renowned tree planting experts, Eden Reforestation Projects and source Gold Standard certified carbon credits for sustainability. In order to achieve this during 2021, they planted a tree for every single client and pledge to do this every year to continue to reduce their carbon footprint.
They have also adapted working environments to assist with becoming carbon neutral such as switching to recycled and environmentally-friendly stationery, reducing paper consumption and beginning to alter offices to renewable electricity.
James Peach, Partner and Head of CSR at Kreston Reeves said;
“We’re really proud as a firm to have achieved this initial target. Our people are passionate about continuing to reduce our emissions and our impact on our environment, so we won’t be stopping here. We know there is still more work that can be done.”
Dan Firmager, Audit Senior and member of the CSR team comments;
“By using Ecologi we are ensuring we only purchase the highest quality genuine carbon credits. Each year we will continue to offset our verified carbon emissions and we also remain committed to planting a tree for each of our clients, every year.”
April 29, 2022
A4 GroUP was established in 2021 by merging two companies with more than 15 years of tradition in the market which created one of the largest consulting companies in Slovakia, providing audit, tax advisory, legal and accounting services, payroll services and specialist services such as ESG reporting and cybersecurity. It advises a range of companies and government institutions, including Bratislava’s international airport, The City of Bratislava, The Slovak Republic’s Ministry of Justice, the Supreme Court of the Slovak Republic, and the National Bank of the Slovak Republic, on multiple issues of data security.
The A4 GroUP has 44 employees, and five founding partners, including Head of Advisory Julius Cincala.
A4 GroUP is rebranding as Kreston Slovakia to be able to better serve its international clients looking for global reach
Liza Robbins, Chief Executive of Kreston Global, said:
“It is with great pleasure that I welcome A4 GroUP to the Kreston Global network. We are experiencing an unprecedented level of growth, a tribute to the exciting work carried out across the network in recent months and years. We will be working with our newest colleagues to build their links across the network as they explore new opportunities both at home and abroad.”
Julius Cincala, Partner and Head of Advisory at A4 Gro, said:
“Kreston Global are an established presence throughout the world and as such they were our first port of call when we made the decision to build our international profile. We look forward to supporting our existing and future clients in their aspirations in the region.”
April 26, 2022
LONDON – Kreston Global has appointed Sue Staunton and Scott Miles co-chairs of its new Life Sciences and Healthcare sector group.
The group has formed in recognition of the substantial life sciences and healthcare work carried out by Kreston firms internationally, providing a wealth of expertise to privately owned businesses and investors looking to invest and raise capital in this rapidly growing sector.
Sue Staunton is a joint managing partner of James Cowper Kreston, and Scott Miles is a corporate partner in Kreston Reeves, both UK accounting firms and members of the Kreston Global network. They will be leading an international group of sector experts from Switzerland, India, Singapore, the US, UK and Germany.
Sue qualified as a chartered accountant with a UK top six firm and held various positions within that business, culminating as National Client Service Director of their technology team, which she co-founded, before leaving to join James Cowper Kreston which has a strong Technology and Life Science cross-disciplinary specialist team which she led for many years. She provides support for Life Science businesses at all stages of their development from start-up to IPO and has significant experience in working with Government funded bodies operating within the sector such as the Vaccine Manufacturing and Innovation Centre and the Rosalind Franklin Institute as well as VC backed private companies- including a number associated with vaccine development.
Scott is the Life Science Lead Partner at Kreston Reeves, where he has developed a specialist team (supported by David Rosevear) to deliver expert services to the Life Science and Healthcare sectors. He and the team have developed significant relationships with Venture Capital organisations, Family offices, Government organisations and High Net Worth Individuals.
Scott provides support to start ups with seed funding through to Series A & B raises and onto listings. He was involved with one of the largest Life Science listings in 2021 with 10 entities being rolled up and listed. He also acted for one of the UK’s largest growing Healthcare providers and supported them with a partial exit in 2021.
2021 saw the Kreston Global network celebrating its 50th anniversary as well as undergoing its own rebrand.
Sue Staunton said:
“Kreston Global has long had an excellent profile in the Life Sciences space and with this focussed sector group we will be able to take our offering to the next level. This is an exciting time for the Life Sciences and Healthcare sector, and Kreston Global’s dynamism makes us a natural partner for clients in the space. I look forward to working with Scott to harness the strength of our global network.”
Scott Miles said:
“Kreston Global’s experience in the sector, and forward-looking ethos, mean that we are superbly well placed to offer a unique global offering to clients in the Life Sciences and Healthcare sector. I look forward to working with Sue and the other members of the group to develop our existing practice and support clients on their journeys.”
Liza Robbins, Chief Executive of Kreston Global, said:
“Sue and Scott have a wealth of experience in the sector and have already done much to develop Kreston Global’s offering. The establishment of a sector group is the natural next step to ensure that we are reaching the right audiences and offering the right services. I would like to congratulate them on their appointments and wish them well as they harness the potential of the network in this exciting area.”
Theo is a non-executive board member of the Cyprus Securities and Exchange Commission (CySEC), and leads the Audit Committee of CySEC. In 2018, he was appointed as the Finance Director of one of the biggest football clubs in Cyprus, Anorthosis Famagusta (Football) Public Limited.
Theo’s portfolio covers M&A due diligence, investment appraisals, forensic audit, internal audit and risk management advice, as well as corporate governance best practice.
In my view, today’s SMEs lack the knowledge and expertise to understand what net-zero really means and this creates a significant knowledge gap. The gap is widened depending on the industry where the SMEs are involved. The more complex the industry the business operates in, the wider the gap becomes. For example, a service provider like a law firm has a much easier task in identifying their footprint and taking action in achieving net-zero compared to a HORECA business where more complex areas are involved in achieving net-zero such as for example food waste management. The majority of SMEs at the moment are proactive on their CSR plan which also involves environmental initiatives but without any real measure of their contribution.
The knowledge gap is a result of the fact that many jurisdictions of today are yet to introduce mandatory ESG compliance reporting and therefore the majority of businesses of this size would currently have ‘net zero’ targets as a secondary priority. Take, for example, the European Union’s directive on environmental reporting which currently provides some guidance but still lacks the appropriate support required. This is further enhanced by the need that all EU members have to transpose the directive into local legislation and this is still in progress.
The challenges faced by SMEs compared to their large corporate counterparts is that a large corporation has the resources and tools to be able to assess its carbon footprint and be able to take mitigation measures whereas an SME would have net zero as a secondary priority and would not invest in such tools or resources.
Small and medium-sized accountants can support their SME clients by being proactive and promoting the importance of assessing their environmental impact and providing knowledge guidance which will effectively reduce the knowledge gap. In addition, an accountant can act as a cost-effective solution for SMEs by providing services that will assist these businesses to assess their risk and impact, and provide mitigating solutions, compared to the higher cost of having in-house resources for this specific task.
Theo is a non-executive board member of the Cyprus Securities and Exchange Commission (CySEC), and leads the Audit Committee of CySEC. In 2018, he was appointed as the Finance Director of one of the biggest football clubs in Cyprus, Anorthosis Famagusta (Football) Public Limited.
Theo’s portfolio covers M&A due diligence, investment appraisals, forensic audit, internal audit and risk management advice, as well as corporate governance best practice.
April 22, 2022
What is a family office?
“Family offices are typically viewed as being somewhat of an enigma” – Preqin Family Offices Survey 2010.
Although the concept of a family office has been in place for centuries, the modern understanding of a family office can be attributed to JP Morgan and JD Rockefeller.
While each family office is considered to be unique (in their source/category, size, structure, strategy), they do share many qualities with respect to working practices;
The notion of a family office is attributed to any group of professionals (who can be legal, tax, investment, concierge, estate planning, charitable giving advice, etc) who provide professional and/or personal dedicated services to a family.
Family office characteristics
One can categorise family offices in
1. Single-family offices (traditional family office) (SFO)
Citi private bank and Union bank place the number of single-family offices around the world to an estimated 10,000 (with about 6,000 in the US according to Deloitte) who serve families with more than 200m USD.
2. Multifamily offices (MFO)
These perform most functions of a single-family office serving a limited number of families (usually for assets more than 20m)
3. Outsourced family office
This is basically a cooperation of the different professionals (ie: legal, tax, investment etc) who are not under the same roof/structure
There is no specific structure/model used for family offices with various options being used:
· Private family trust companies
· Family investment companies
· Investment funds
· Foundations
· Holding companies limited by guarantee
Benefits of a family office compared to other models
Family offices, going from outsourced to MFO, to SFO have increased benefits on each step-up.
It is built around the family’s needs whatever they may be (hence the uniqueness of each family office)
It provides a dedicated team of highly skilled professionals who have the time to obtain a deeper understanding of the family’s needs, risk tolerance and other investment principles of the family’s wealth.
Confidential and private information is only shared by a small group of individuals who work for the company.
There is more control of the assets and investments making it easier to limit risk exposure in all aspects (tax/legal/financial etc)
It provides the owners with time to carry on with their daily lives knowing that all their affairs (personal, family wealth, family succession and others) are handled by this specialised group of people.
Family office jurisdiction considerations
Due to its perpetuity, a family office (MFO/SFO) is never actually a single office or building and may span more than one country depending on the needs of the family.
The main office selection is a complex and challenging exercise taking into account factors such as availability of a skilled workforce and professional services, regulatory and tax framework, political stability, immigration rules and cultural aspects amongst others.
Cyprus as an ideal location for a family office
Cyprus ticks all the aforementioned “consideration” boxes that a family needs to take into account before taking the next step in their family planning.
As an EU member, Cyprus follows EU directives and OECD guidance and has a wide range of Double tax Treaty Network as well as numerous corporate and individual tax incentives, with its legal and tax system modelled on the English and common law system.
Having the 2nd highest tertiary educational attainment rate in the EU makes it very easy to find highly skilled professionals both in terms of management and attaining high-quality professional services.
How we can help
At Kreston Ioannou & Theodoulou we understand that family offices must be designed based on the specific needs, circumstances and concerns of the families they serve.
Our multidisciplinary team can assist in the design of the structure that fits the specific family needs and provide ongoing support to the family office for example for asset protection, succession planning, family governance, tax planning and more. Our team is here to help you.
David Whitmer has more than 20 years of experience in transfer pricing consulting services, primarily with large international accounting firms, covering transfer pricing planning, intellectual property valuation, financial modelling, and transfer-pricing disputes in a number of industries, including finance, chemicals, pharmaceuticals, software, manufacturing, services and tax-exempt organizations.
What is transfer pricing?
In simple terms, transfer pricing is the process of setting the prices charged between associated enterprises in cross-border transactions, which can involve transfers of tangible goods, services, and intangible property, as well as financing transactions.
When a cross border transaction occurs between associated enterprises, tax administrations in the respective countries are especially interested to ensure that the taxable profits of multi-national enterprises (“MNEs”) are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country yield results that are consistent with the economic activity undertaken and the results that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances.
What are the rules?
Each country has different transfer pricing rules, so it is important to speak to a country tax specialist to make sure you are following local country requirements. With only a few exceptions, most countries’ transfer pricing rules are based on the “arms-length” principle, where pricing between associated enterprises should reflect the prices that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances
The OECD has also published transfer pricing guidelines (“OECD Guidelines”) here for member countries and cooperating non-member countries to follow. Most countries’ transfer pricing rules are based on the OECD Guidelines, though there may be certain differences in interpretation, application, and administration among countries.
If the transfer price is not arm’s length, the tax administrator has the authority under the tax jurisdiction regulations to make adjustments by reallocating items of gross income, deductions, credits, or allowances in order to properly reflect income between the entities.
What is an example of transfer pricing?
The following case illustrates various examples of transfer pricing related issues:
A MNE group, ValveCo, is in the business of designing, producing, and selling valves. ParentCo is responsible for design, manufacture, and distribution in its territory. SubCo1 operates as a licensed producer in its jurisdiction (Transaction 1). SubCo1 performs certain development work under the direction of ParentCo (Transaction 2). SubCo1 purchases components from ParentCo to be used in its manufacturing process (Transaction 3). SubCo1 relies on ParentCo for certain management and administrative functions (Transaction 4), as well as funding of its operations (Transaction 5). SubCo2 purchases products from ParentCo and SubCo1 for resale to third-party customers in its jurisdiction (Transaction 6).
Who do the transfer pricing rules apply to?
The transfer pricing rules are relevant to MNEs with controlled transactions among associated enterprises in different tax jurisdictions. Uncontrolled transactions do not fall under transfer pricing rules. A transaction is controlled or enterprises are associated if one enterprise participates in the management, control, or ownership of another enterprise, or if the same people or enterprise participates in the management, control, or ownership of two enterprises (i.e., a situation with common ownership).
Are there exemptions?
A growing number of countries are implementing contemporaneous transfer pricing documentation requirements, meaning the transfer pricing documentation has to be prepared prior to the filing of the tax return for a given accounting period. However, certain jurisdictions do provide documentation exemptions for small and medium-sized enterprises. In addition, a handful of other countries do not require contemporaneous documentation. While these exemptions exist, the burden of proof remains with the taxpayer to demonstrate arm’s-length pricing. This supporting information may still be requested during a transfer pricing examination, and the intercompany pricing may be adjusted by the examiner to reflect an arms-length outcome.
How do you calculate transfer pricing?
As noted above, associated enterprises should price transactions in the same way that uncontrolled entities would price the same transactions under similar circumstances. In short, the arm’s-length principle requires the comparison of controlled transactions with uncontrolled transactions. Hence, transfer prices are calculated through “comparability analysis” or benchmarking analysis. Valid comparables or benchmarks may exist as transactions between an associated enterprise and third parties (i.e., internal comparables). Alternatively, external comparables may be applied in the form of external comparable uncontrolled transactions (where none of the parties involved are members of the MNE group) or independent comparable companies that perform similar functions to one of the associated enterprises (i.e., the tested party). Our transfer pricing specialists can evaluate the specified transfer pricing methods and comparability criteria to identify the most reliable transfer pricing approach for a specific client. For external comparables, our transfer pricing specialists have access to specially licensed databases to conduct our benchmarking research. Please contact your nearest Kreston Global office to assist with your transfer pricing compliance needs.
Is transfer pricing tax evasion?
The objective of transfer pricing rules is to prevent MNEs from arbitrarily shifting income to avoid paying taxes. According to the OECD Guidelines, the consideration of transfer pricing should not be confused with the consideration of problems of tax fraud or tax avoidance, even though transfer pricing policies may be used for such purposes. Application of transfer pricing in accordance with the arm’s-length principle and the preparation of supporting documentation is considered to maintain tax compliance and good practice; failure to do so may result in income adjustments, potential double taxation, interest, and penalties.
How can Kreston Global help my company with transfer pricing?
Kreston firms can help support your company to adhere to country-based transfer pricing rules with the following core services:
Please search for your nearest Kreston Global office here and they can help signpost you to the countries you need support in.
ESG accounting practices are coming in to sharp focus, driven by climate change legislation to deliver net-zero. The 2050 deadline agreed by the 193 countries that are signed up to the Paris agreement is already impacting larger multi-national corporations who are changing the way they operate. SMEs and the supply chain eco-system are next to feel this change. This “trickle-down” effect means that it is no longer just affecting the Big Four.
Neil Johnson, a freelance journalist, recently covered the subject in an article on the ACCA website here, where he interviewed Kreston Global member, Kreston Reeves, on their journey to net-zero. They commented,
“There is evidence from many businesses, including Kreston Reeves, that by becoming carbon neutral (or aiming for net-zero) can be hugely beneficial. For example, this can be a big attraction for new candidates/employees to join the business. In addition, it can help improve retention rates of staff if an employer can demonstrate strong social responsibility practices,” said Corporate Partner James Peach and audit senior Dan Firmager.
An accountancy practice’s client base is a great audience with which to share a net-zero story, in the hope that it will resonate with some and may lead to action from others to help support climate action.
Internally, it can be galvanising tool that strengthens and enforces company culture.
Kreston Reeves continues to focus on reducing carbon to work towards the more stringent goal of net-zero. “We are very keen to focus more on our carbon output and to minimise this as far as possible. This is part of our assessment of net-zero and how we can achieve this. It is important that every business or individual does not become complacent and simply rely on the ability to offset whatever CO2 is emitted. The more than can be done to reduce emissions, the better result for the environment and for our future
generations,” said corporate partner James Peach and audit senior Dan Firmager.
There are online carbon calculators for businesses, such as this from the Carbon
Trust: https://www.carbontrust.com/resources/sme-carbon-footprint-calculator or the government’s MacKay carbon calculator: https://www.gov.uk/guidance/carbon-calculator.
April 21, 2022
