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R (Newcastle United Football Club and others) v HMRC and the Crown Court at Leeds

In R (Newcastle United Football Club and others) v HMRC and the Crown Court at Leeds [2017] EWHC 2402 (4 October 2017) the High Court confirmed the validity of search and seizure warrants issued to HMRC under the Police and Criminal Evidence (PACE) Act 1984 Sch 1.

Newcastle United Football Club (‘Newcastle’) challenged the validity of HMRC’s decision to apply for search and seizure warrants issued in connection with a criminal investigation of suspected evasion of VAT income tax and NICs in relation to payments made to footballers and their agents. The investigation was known as ‘Operation Loom’ and it involved inter alia investigating whether the arrangements were structured so that a smaller fee appeared to be paid to the player’s agent and a larger fee to Newcastle’s agent out of which Newcastle secretly paid players and/or their agents.

Newcastle relied on five grounds...

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