Grant Ambridge and Andy Rootsey, assisted by Erhin McCadden-Finnerty, Amy Bromwich, Elona Morina and Lauren Mesure represent ‘W’ in a complex Very High-Cost Case.
Our client is one of 20 defendants in an HMRC prosecution alleging conspiracies to cheat the public revenue between 2017 and 2019. The Crown alleges VAT and National Insurance Contribution losses of just under £100,000,000. HMRC’s criminal investigation ran for nearly six years before charge.
The defendants say they operated a mini-umbrella company model that had been reviewed and approved by a leading tax advice specialist, who in turn instructed a leading KC specialising in tax. The Crown’s case is that the model was a fraud: that the group controlled not only the outsourcing companies but also the sourcing companies and the micro-employers, so that there was no genuine supply of labour at either level.
The case raises a number of key issues and complexities including the structure and nature of the supply chains, the scale involving tens of thousands of temporary workers, hundreds of micro-employers, and a very large volume of material on money flows, VAT accounting and PAYE and NIC deductions.
The case involves novel questions of fact and law including whether supplies of labour were genuine, and the weight to be given to professional tax advice obtained in advance, which go to the heart of the dishonesty and agreement elements of the conspiracy.
The indictment has been divided into three separate trials; Trial 1 alone is estimated at six months or more.
Operation Salmon is among the largest HMRC labour-supply prosecutions currently before the courts.
The case continues
Roderick James and Libby Anderson of Crucible Chambers are Instructed Counsel
