FRAUD

Amit Puri

Amit Puri (Pure Tax Investigations) outlines the structure, resourcing and recent performance of HMRC’s Customer Compliance Group, including trends in compliance yield and investigation activity.

Rebekka Sandwell Robert Waterson Ed Griffiths

The ruling in Hotelbeds underscores the public law duty on HMRC to exercise their functions fairly, rationally and reasonably, write Robert Waterson and Ed Griffiths (Eversheds Sutherland).

Nicholas Gardner

Ruby Hamid

The new fraud offence is a notable expansion of the failure to prevent (FTP) model creating corporate criminal liability. Ruby Hamid and Nicholas Gardner (Ashurst) examine actions for companies, and compare the rules with the existing FTP offences for bribery and tax evasion.

Michael Paulin

Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s broader view of tax fraud in its updated COP 9.

SKAT fraud claim survives issue estoppel challenge: Readers may recall SKAT’s attempt to pursue a fresh fraud claim in England against MCML, formerly ED&F Man Capital Markets Ltd, over allegedly false tax vouchers used to obtain Danish...

Tim Sarson

Tim Sarson (KPMG) reviews the Biden Administration’s FY 2025 tax proposals and the OECD’s new guidance on Amount B of Pillar One.

Michelle Sloane

Adam Craggs

Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.

Zoe Gascoyne

Zoe Gascoyne (HMRC) explains the importance of understanding the revised COP 9 and the contractual disclosure facility offer made as part of the process.

Dominic Stuttaford

Dominic Stuttaford (Norton Rose Fulbright) considers the scope of a new ‘failure to prevent’ offence and how it differs from the existing corporate criminal offences.