Four KPMG Belfast partners arrested in tax investigation…

Interesting developments in Belfast this afternoon (H/T Doug)…

Disputes between the big accountancy companies and and tax authorities are common enough. But the decision by HM Revenue and Customs to visit the Belfast offices of KPMG on Wednesday and arrest four senior partners there for questioning on suspected tax evasion is a most unusual development and one which creates a serious issue for the firm and, of course, for the individuals themselves.

The HM Revenue and Customs has picked high-profile targets. The four arrested included KPMG Belfast’s chairman, Jon D’Arcy and the head of its tax practice and a high profile figure in the North’s corporation tax debate, Eamonn Donaghy. Also questioned were Paul Hollway, who heads KPMG’s corporate finance business in Ireland and a fourth senior partner, Arthur O’Brien.

The Revenue authorities visited the KPMG officers to arrest the four for questioning. KPMG said in a statement that there was no indication that the investigation related to the business of the company or its dealings with clients.

Cliff Taylor adds…

The public nature of the action generates a significant issue for KPMG, which responded quickly by placing the four on administrative leave. The question now is what happens next and how quickly it will emerge whether further action will follow yesterday’s questioning.

  • barnshee

    HMRC could end up with serious egg on face here These need to be copper fastened arrests.

    These are top drawer tax professionals well qualified and experienced normally well beyond HMRC staff
    Watch this space

  • murdockp

    There is always another story and agenda in NI. The next chapter is awaited with interest

  • mickfealty

    I don’t think it has anything much to do with the day job though Barnshee…

  • chrisjones2

    So are they investigating their own tax affairs or those of others? This should be interesting

  • SDLP supporter

    I’ve been a chartered accountant for four decades and I can never recall anything like this ever happening, either in Belfast or elsewhere. It’s a reasonable presumption it does not relate to client affairs. The best commentary on the often outrageous tax “planning” of the Big Four accountancy practices in London is in Private Eye and the sums involved are eye-watering, into the billions. Belfast is very small beer in relation to financial services and tax planning. If it’s just the local HMRC involved, they need to be very careful, for these guys’ professional reputations have been harmed in a small society like ours and, in fairness, they are very able people. They’re entitled to the presumption of innocence and I wonder how and why this story got into the public domain.

    Decades ago, the Inland Revenue people (as it was then) were the smartest public servants you could ever come across. That reputation has been frittered away in the interim: I personally date it when they began to talk about ‘customers’ rather than ‘clients’ and stopped being watchdogs for the public interest to collect the optimum tax consonant with compliance with the law.

  • barnshee

    There are hints in the Tele that a property company with massive losses -run by the parties -MAY be involved

  • eac1968

    If nothing comes of these arrests then the PSNI and HMRC will be in big trouble (and rightly so). As you say, their professional reputations have been called into question, just by the very fact of the detail of the arrests being in the public domain.

    I was at Queen’s with one of the individuals concerned, and I would be very surprised to hear of him being involved with anything not 100% above board. As Mick has said, the public hints indicate that the investigation is not related to their work for KPMG. That begs the question as to why the arrests took place at KPMG offices and why the details released to the media make such a big thing of where they work. Surely the more appropriate way of doing things would have been to quietly invite them to attend a PSNI station for questioning? The method used suggests to me that the negative publicity was intended. That being the case, it is another indication of ‘something being badly wrong in the state of Denmark’, as they say.

  • SDLP supporter

    I don’t think the PSNI are involved, AFAIK?

  • Robin Keogh

    Quite clearly its Sinn Fein’s fault

  • SeaanUiNeill

    “These are far more important human beings than those challenging them” really is not an argument banshee. We need to know just why something as drastic as this seemed to be necessary. And the very fact that such public finger pointing is so very different to customary HMRC practice should suggest that until we know, it’s a hostage to fortune to suggest that all that smoke may not, perhaps, have even a few smouldering ashes somewhere.

    “Watch this space”……..

  • Sergiogiorgio

    Careful Seaan, you’ll be letting that big business conspiracy theory of yours get you all in a tissy this early in the morning. Have a cup of tea dear and calm down.
    I agree though, it’s making for a great story…..

  • SeaanUiNeill

    SG, are you really even just obliquely defending such a macho statement as “These are top drawer tax professionals well qualified and experienced normally well beyond HMRC staff”.

    The “Top drawer Professionals” tag says nothing whatsoever about the probity or not of their business practice, so this sort of comment is meaningless unless barnshee’s suggesting that they are clever enough to get away with worrying things. Having been a “Top Drawer Professional” a short while back myself, managed films and negotiated major budgets, along with knowing any number of accountants, fund managers and even quite a few “serious’ bankers socially, I’ve found that what I’ve encountered in meetings and how my acquaintances talk privately does very little to reassure me about the moral probity of people at this level of financial management. No big sit-down conspiracy, but a lot of worrying attitudes across the board (and boards). But even with this ” it’s making for a great story…..”, delighted to agree on that!

    Coffee man myself, first half pint of ground Ethiopian Harar already downed by 7.00am. Tea is for wimps………

  • SeaanUiNeill

    SG, are you really even just obliquely defending such a macho statement as “These are top drawer tax professionals well qualified and experienced normally well beyond HMRC staff”.

    The “Top drawer Professionals” tag says nothing whatsoever about the probity or not of their business practice, so this sort of comment is meaningless unless barnshee’s suggesting that they are clever enough to get away with worrying things. Having been a “Top Drawer Professional” a short while back myself, managed films and negotiated major budgets, along with knowing any number of accountants, fund managers and even quite a few “serious’ bankers socially, I’ve found that what I’ve encountered in meetings and how my acquaintances talk privately does very little to reassure me about the moral probity of people at this level of financial management. No big sit-down conspiracy, but a lot of worrying attitudes across the board (and boards). But even with this ” it’s making for a great story…..”, delighted to agree on that!

    Coffee man myself, first half pint of ground Ethiopian Harar already downed by 7.00am. Tea is for wimps………

  • SeaanUiNeill

    Well, Robin, they are supposed to be 49.5% in charge up north……….

  • Nevin

    Seaan, Kevin Magee will be looking up his old files.

  • Reader

    tiocfaidh Armani

  • Reader

    tiocfaidh Armani

  • Dev32

    The Irish Times has the most colour on this story. It appears that the company set up by the four men was making loans to other developers. It was also trading at a large loss – over 4million and strangely had a trading address at the same address as KPMG in Belfast…..

  • Dev32

    The Irish Times has the most colour on this story. It appears that the company set up by the four men was making loans to other developers. It was also trading at a large loss – over 4million and strangely had a trading address at the same address as KPMG in Belfast…..

  • Sergiogiorgio

    Half a pint of coffee by 0700 old chap! That will explain the wild associations. No, I wasn’t defending the “comment”, more the HMRC approach. It will play out as it plays out – very early days.

  • Sergiogiorgio

    Half a pint of coffee by 0700 old chap! That will explain the wild associations. No, I wasn’t defending the “comment”, more the HMRC approach. It will play out as it plays out – very early days.

  • 23×7

    We are long over due a major investigation into the behavior of the “Big Four”. I can only assume the failure to do so is due to their lobbying and donership to UK political parties.

    http://powerbase.info/index.php/Big_Four_Accountancy_firms:_Donations_to_UK_political_parties_2010-2015

    These organizations are no strangers to breaking the law here in N.I..The treatment of Nortel workers by E&Y being the perfect example.

    http://www.thompsons.law.co.uk/ntext/protective-award-payments-redundant-workers.htm

  • 23×7

    We are long over due a major investigation into the behavior of the “Big Four”. I can only assume the failure to do so is due to their lobbying and donership to UK political parties.

    http://powerbase.info/index.php/Big_Four_Accountancy_firms:_Donations_to_UK_political_parties_2010-2015

    These organizations are no strangers to breaking the law here in N.I..The treatment of Nortel workers by E&Y being the perfect example.

    http://www.thompsons.law.co.uk/ntext/protective-award-payments-redundant-workers.htm

  • Reader

    Interesting links. Looks like PWC is shovelling money primarily to Labour, though not in the form of actual donations.
    Is it an accident that the Powerbase website looks so much like Wikipedia?

  • Reader

    Interesting links. Looks like PWC is shovelling money primarily to Labour, though not in the form of actual donations.
    Is it an accident that the Powerbase website looks so much like Wikipedia?

  • Reader

    Interesting links. Looks like PWC is shovelling money primarily to Labour, though not in the form of actual donations.
    Is it an accident that the Powerbase website looks so much like Wikipedia?

  • Reader

    eac1968: If nothing comes of these arrests then the PSNI and HMRC will be in big trouble (and rightly so). As you say, their professional reputations have been called into question, just by the very fact of the detail of the arrests being in the public domain.
    These 4 people have exactly the same legal rights as any 4 drunks dragged out of the Botanic Inn after closing time. And that’s exactly the way it should be.
    As for whether it works out like that in practice, I’ll wait and see.

  • Reader

    eac1968: If nothing comes of these arrests then the PSNI and HMRC will be in big trouble (and rightly so). As you say, their professional reputations have been called into question, just by the very fact of the detail of the arrests being in the public domain.
    These 4 people have exactly the same legal rights as any 4 drunks dragged out of the Botanic Inn after closing time. And that’s exactly the way it should be.
    As for whether it works out like that in practice, I’ll wait and see.

  • Reader

    eac1968: If nothing comes of these arrests then the PSNI and HMRC will be in big trouble (and rightly so). As you say, their professional reputations have been called into question, just by the very fact of the detail of the arrests being in the public domain.
    These 4 people have exactly the same legal rights as any 4 drunks dragged out of the Botanic Inn after closing time. And that’s exactly the way it should be.
    As for whether it works out like that in practice, I’ll wait and see.

  • hugh mccloy

    How many gov reviews have KPMG been paid to do and been paid for a particular outcome. Also how many KPMG bigwigs now hold senior posts in government

  • hugh mccloy

    How many gov reviews have KPMG been paid to do and been paid for a particular outcome. Also how many KPMG bigwigs now hold senior posts in government

  • hugh mccloy

    How many gov reviews have KPMG been paid to do and been paid for a particular outcome. Also how many KPMG bigwigs now hold senior posts in government

  • hugh mccloy

    How many gov reviews have KPMG been paid to do and been paid for a particular outcome. Also how many KPMG bigwigs now hold senior posts in government

  • hugh mccloy

    How many gov reviews have KPMG been paid to do and been paid for a particular outcome. Also how many KPMG bigwigs now hold senior posts in government

  • NMS

    KPMG Belfast is part of the Irish partnership and not the UK operation https://www.kpmg.com/IE/en/about/Pages/Default.aspx . The investigation appears most likely refer to their personal affairs, there is no suggestion that the KPMG Ireland is involved. I suppose if you are pulling the best part €1M per annum, you end up paying a lot of tax, unless you become creative. Perhaps creativity went too far?

  • NMS

    KPMG Belfast is part of the Irish partnership and not the UK operation https://www.kpmg.com/IE/en/about/Pages/Default.aspx . The investigation appears most likely refer to their personal affairs, there is no suggestion that the KPMG Ireland is involved. I suppose if you are pulling the best part €1M per annum, you end up paying a lot of tax, unless you become creative. Perhaps creativity went too far?

  • NMS

    KPMG Belfast is part of the Irish partnership and not the UK operation https://www.kpmg.com/IE/en/about/Pages/Default.aspx . The investigation appears most likely refer to their personal affairs, there is no suggestion that the KPMG Ireland is involved. I suppose if you are pulling the best part €1M per annum, you end up paying a lot of tax, unless you become creative. Perhaps creativity went too far?

  • NMS

    KPMG Belfast is part of the Irish partnership and not the UK operation https://www.kpmg.com/IE/en/about/Pages/Default.aspx . The investigation appears most likely refer to their personal affairs, there is no suggestion that the KPMG Ireland is involved. I suppose if you are pulling the best part €1M per annum, you end up paying a lot of tax, unless you become creative. Perhaps creativity went too far?

  • NMS

    KPMG Belfast is part of the Irish partnership and not the UK operation https://www.kpmg.com/IE/en/about/Pages/Default.aspx . The investigation appears most likely refer to their personal affairs, there is no suggestion that the KPMG Ireland is involved. I suppose if you are pulling the best part €1M per annum, you end up paying a lot of tax, unless you become creative. Perhaps creativity went too far?

  • SeaanUiNeill

    Thought we might be on the same page here pretty much on my second reading of your comment, SG, but hey, its good to get these things out on the page……

    That most insightful of English language poets (in his own assessment “a far greater poet than Shakespere”) the adamantine Alex Pope might just differ from you however in his own assessment of the effect of my early morning half-pint:

    “Coffee, which makes the politicians wise,
    And see through all things with his half-shut eyes.”

  • SeaanUiNeill

    Thought we might be on the same page here pretty much on my second reading of your comment, SG, but hey, its good to get these things out on the page……

    That most insightful of English language poets (in his own assessment “a far greater poet than Shakespere”) the adamantine Alex Pope might just differ from you however in his own assessment of the effect of my early morning half-pint:

    “Coffee, which makes the politicians wise,
    And see through all things with his half-shut eyes.”

  • SeaanUiNeill

    Thought we might be on the same page here pretty much on my second reading of your comment, SG, but hey, its good to get these things out on the page……

    That most insightful of English language poets (in his own assessment “a far greater poet than Shakespere”) the adamantine Alex Pope might just differ from you however in his own assessment of the effect of my early morning half-pint:

    “Coffee, which makes the politicians wise,
    And see through all things with his half-shut eyes.”

  • SeaanUiNeill

    Thought we might be on the same page here pretty much on my second reading of your comment, SG, but hey, its good to get these things out on the page……

    That most insightful of English language poets (in his own assessment “a far greater poet than Shakespere”) the adamantine Alex Pope might just differ from you however in his own assessment of the effect of my early morning half-pint:

    “Coffee, which makes the politicians wise,
    And see through all things with his half-shut eyes.”

  • SeaanUiNeill

    Thought we might be on the same page here pretty much on my second reading of your comment, SG, but hey, its good to get these things out on the page……

    That most insightful of English language poets (in his own assessment “a far greater poet than Shakespere”) the adamantine Alex Pope might just differ from you however in his own assessment of the effect of my early morning half-pint:

    “Coffee, which makes the politicians wise,
    And see through all things with his half-shut eyes.”

  • SeaanUiNeill

    Thank you Nevin for the interesting elucidation…..

    It always astonishes me just how many of my friends who are financial high flyers seem to haunt casinos! They even ask me occasionally, perhaps as some leftist male equivalent of Lady Luck’s most negative incarnation. My own personal luck is so utterly poor, perhaps they are hoping I will prove a more attractive host to draw off any bad luck that might be eyeing them up.

  • SeaanUiNeill

    Thank you Nevin for the interesting elucidation…..

    It always astonishes me just how many of my friends who are financial high flyers seem to haunt casinos! They even ask me occasionally, perhaps as some leftist male equivalent of Lady Luck’s most negative incarnation. My own personal luck is so utterly poor, perhaps they are hoping I will prove a more attractive host to draw off any bad luck that might be eyeing them up.

  • SeaanUiNeill

    Thank you Nevin for the interesting elucidation…..

    It always astonishes me just how many of my friends who are financial high flyers seem to haunt casinos! They even ask me occasionally, perhaps as some leftist male equivalent of Lady Luck’s most negative incarnation. My own personal luck is so utterly poor, perhaps they are hoping I will prove a more attractive host to draw off any bad luck that might be eyeing them up.

  • SeaanUiNeill

    Thank you Nevin for the interesting elucidation…..

    It always astonishes me just how many of my friends who are financial high flyers seem to haunt casinos! They even ask me occasionally, perhaps as some leftist male equivalent of Lady Luck’s most negative incarnation. My own personal luck is so utterly poor, perhaps they are hoping I will prove a more attractive host to draw off any bad luck that might be eyeing them up.

  • SeaanUiNeill

    Thank you Nevin for the interesting elucidation…..

    It always astonishes me just how many of my friends who are financial high flyers seem to haunt casinos! They even ask me occasionally, perhaps as some leftist male equivalent of Lady Luck’s most negative incarnation. My own personal luck is so utterly poor, perhaps they are hoping I will prove a more attractive host to draw off any bad luck that might be eyeing them up.

  • Nevin

    They may be in more need of a reverse Ferret than a Jeap financial vehicle to get themselves of this predicament., Seaan. The net widens.

  • Nevin

    They may be in more need of a reverse Ferret than a Jeap financial vehicle to get themselves of this predicament., Seaan. The net widens.

  • Nevin

    They may be in more need of a reverse Ferret than a Jeap financial vehicle to get themselves of this predicament., Seaan. The net widens.

  • Nevin

    They may be in more need of a reverse Ferret than a Jeap financial vehicle to get themselves of this predicament., Seaan. The net widens.

  • Nevin

    They may be in more need of a reverse Ferret than a Jeap financial vehicle to get themselves of this predicament., Seaan. The net widens.

  • Greenflag 2

    “and strangely had a trading address at the same address as KPMG in Belfast…..”

    Brilliant idea -that would keep down their overhead costs 😉 and should make finding the paperwork a lot easier unless of course they’ve pulled an Arthur Andersen Enron stroke and shredded the lot before the PSNI arrived . We will not doubt be illuminated further .

  • Greenflag 2

    “and strangely had a trading address at the same address as KPMG in Belfast…..”

    Brilliant idea -that would keep down their overhead costs 😉 and should make finding the paperwork a lot easier unless of course they’ve pulled an Arthur Andersen Enron stroke and shredded the lot before the PSNI arrived . We will not doubt be illuminated further .

  • Greenflag 2

    “and strangely had a trading address at the same address as KPMG in Belfast…..”

    Brilliant idea -that would keep down their overhead costs 😉 and should make finding the paperwork a lot easier unless of course they’ve pulled an Arthur Andersen Enron stroke and shredded the lot before the PSNI arrived . We will not doubt be illuminated further .

  • Greenflag 2

    “and strangely had a trading address at the same address as KPMG in Belfast…..”

    Brilliant idea -that would keep down their overhead costs 😉 and should make finding the paperwork a lot easier unless of course they’ve pulled an Arthur Andersen Enron stroke and shredded the lot before the PSNI arrived . We will not doubt be illuminated further .

  • Greenflag 2

    “and strangely had a trading address at the same address as KPMG in Belfast…..”

    Brilliant idea -that would keep down their overhead costs 😉 and should make finding the paperwork a lot easier unless of course they’ve pulled an Arthur Andersen Enron stroke and shredded the lot before the PSNI arrived . We will not doubt be illuminated further .

  • SeaanUiNeill

    Reader the philosopher T.E. Hulme was once drunkenly relieving himself of an afternoons beer against the railings of Soho Square while waiting for a girlfriend who was working in the Omega Workshop, when he was approached by a tall policeman.
    “You cannot act in this way, sir”, said the guardian of the law.
    “You do realise that you are speaking to a member of the English upper middle class” roared an enraged Hulme, fingering the Gautier-Brzeska Vorticist knuckle-duster in his waistcoat pocket.
    “I’m sorry to have troubled you sir”, the other quickly replied before beating a hasty retreat.

  • SeaanUiNeill

    Reader the philosopher T.E. Hulme was once drunkenly relieving himself of an afternoons beer against the railings of Soho Square while waiting for a girlfriend who was working in the Omega Workshop, when he was approached by a tall policeman.
    “You cannot act in this way, sir”, said the guardian of the law.
    “You do realise that you are speaking to a member of the English upper middle class” roared an enraged Hulme, fingering the Gautier-Brzeska Vorticist knuckle-duster in his waistcoat pocket.
    “I’m sorry to have troubled you sir”, the other quickly replied before beating a hasty retreat.

  • SeaanUiNeill

    Reader the philosopher T.E. Hulme was once drunkenly relieving himself of an afternoons beer against the railings of Soho Square while waiting for a girlfriend who was working in the Omega Workshop, when he was approached by a tall policeman.
    “You cannot act in this way, sir”, said the guardian of the law.
    “You do realise that you are speaking to a member of the English upper middle class” roared an enraged Hulme, fingering the Gautier-Brzeska Vorticist knuckle-duster in his waistcoat pocket.
    “I’m sorry to have troubled you sir”, the other quickly replied before beating a hasty retreat.

  • SeaanUiNeill

    Reader the philosopher T.E. Hulme was once drunkenly relieving himself of an afternoons beer against the railings of Soho Square while waiting for a girlfriend who was working in the Omega Workshop, when he was approached by a tall policeman.
    “You cannot act in this way, sir”, said the guardian of the law.
    “You do realise that you are speaking to a member of the English upper middle class” roared an enraged Hulme, fingering the Gautier-Brzeska Vorticist knuckle-duster in his waistcoat pocket.
    “I’m sorry to have troubled you sir”, the other quickly replied before beating a hasty retreat.

  • SeaanUiNeill

    Reader the philosopher T.E. Hulme was once drunkenly relieving himself of an afternoons beer against the railings of Soho Square while waiting for a girlfriend who was working in the Omega Workshop, when he was approached by a tall policeman.
    “You cannot act in this way, sir”, said the guardian of the law.
    “You do realise that you are speaking to a member of the English upper middle class” roared an enraged Hulme, fingering the Gautier-Brzeska Vorticist knuckle-duster in his waistcoat pocket.
    “I’m sorry to have troubled you sir”, the other quickly replied before beating a hasty retreat.

  • Greenflag 2

    “These need to be copper fastened arrests.”

    They may not have been . I don’t think the PSNI actually handcuffed the 4 or did they 😉 ?. Speed is of the essence in these cases as anyone who still recalls the demise of Arthur Andersen in the Enron fiasco might remember . Shredders and disc wiping etc etc .

  • Greenflag 2

    “These need to be copper fastened arrests.”

    They may not have been . I don’t think the PSNI actually handcuffed the 4 or did they 😉 ?. Speed is of the essence in these cases as anyone who still recalls the demise of Arthur Andersen in the Enron fiasco might remember . Shredders and disc wiping etc etc .

  • Greenflag 2

    “These need to be copper fastened arrests.”

    They may not have been . I don’t think the PSNI actually handcuffed the 4 or did they 😉 ?. Speed is of the essence in these cases as anyone who still recalls the demise of Arthur Andersen in the Enron fiasco might remember . Shredders and disc wiping etc etc .

  • Greenflag 2

    “These need to be copper fastened arrests.”

    They may not have been . I don’t think the PSNI actually handcuffed the 4 or did they 😉 ?. Speed is of the essence in these cases as anyone who still recalls the demise of Arthur Andersen in the Enron fiasco might remember . Shredders and disc wiping etc etc .

  • Greenflag 2

    “These need to be copper fastened arrests.”

    They may not have been . I don’t think the PSNI actually handcuffed the 4 or did they 😉 ?. Speed is of the essence in these cases as anyone who still recalls the demise of Arthur Andersen in the Enron fiasco might remember . Shredders and disc wiping etc etc .

  • Granni Trixie

    I was just thinking that infact I’m thinking of their review of the governance including scrutiny of financial controls of a group to which I have a connection. Their reputation is likely to suffer, impacting on attracting work.

  • barnshee

    er its sfa to do with the cops -its HMRC —who are not famous for getting it right

  • barnshee

    I do not suggest that anyone is more IMPORTANT than anyone else
    From my direct experience HMRC generally do not have an abundance of staff with the qualifications and experience of the parties arrested. Hence my surprise

  • barnshee

    hmm more 4 people arrested for being drunk and found not to be drunk -= cops in dock

  • Old Mortality

    Not quite clever enough to avoid becoming heavily

    exposed to a hugely inflated property market, it seems.

  • Greenflag 2

    They HMRC may sometimes err but they collect a lot of taxes all the same .
    It was a pun 🙂 the copper bit .

  • SeaanUiNeill

    Thank you for the clarification, barnshee. However, while those arrested may have considerable skill in the management of tax law on behalf of clients, if there is provable infringement, the almost free hand HMRC is customarily given in matters of taxation will permit them make the very most of it, so little real skill is required. It’s all a matter of walking stick against cudgel really.

  • SeaanUiNeill

    They don’t have to get it right. With the powers they have, you really don’t.

  • Catcher in the Rye

    HMRC officers, along with police officers and citizens generally, can be prosecuted for making a wrongful arrest. I’d say it’s unlikely that this will happen though.

  • Catcher in the Rye

    they aren’t. HMRC officials have arrest powers.

  • Catcher in the Rye

    That begs the question as to why the arrests took place at KPMG offices and why the details released to the media make such a big thing of where they work.

    Because the four individuals are directors of a company whose registered office is the same as that of the KPMG business.

  • SeaanUiNeill

    CitR, I’d agree with both sentences, especially the last. And you have this interesting thing where you are “guilty” in the light of a tax assessment, unless you can prove yourself “innocent” to their satisfaction, and before the end of the short statutory period in which you may do so.

  • barnshee

    I am afraid I must declare an interest -ahem I used to one of them (shudder )
    It is extraordinarily difficult to prove ” being KNOWINGLY concerned in the evasion of tax” (mens rea etc)

    HMRC usually prefer a negotiated settlement a “civil penalty” where tax is recovered and includes a penalty and interest charged on tax recovered Case closed- no publicity– no court or tribunal

    Court (and Trib) cases might be lost -Juries are notoriously unsympatheic to HMRC hence my surprise at the high profile actions of HMRC. I would wager HMRC will have difficulty making any charges stick.

  • SeaanUiNeill

    I entirely agree, banshee, which is why I’m interested that this tack has been taken, rather than the usual methods of negotiation. There are several reasons I can think of, all of them flagging very serious breaches of tax law.

    I know no more of the situation that everyone else who is an outsider, but there are I believe a few serious issues of law where HMRC has no other choose but to prosecute. But, as you say, time will tell.