Les Howard reviews the Sandham Upper Tier case and explains its implications for partnership liability.
In her recent study (‘Tax Fraud and Selective Law Enforcement’) tax academic Rita de la Feria comments that HMRC fraud management has tended to make innocent victims of fraudulent behaviour liable for the VAT losses. This is much cheaper than prosecuting the perpetrators and recovering the stolen money. In practice, this approach leaves some taxpayers vulnerable to substantial financial losses.
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