In the 2016 Budget, the Chancellor announced proposed legislation to tackle so-called
“disguised remuneration”. HMRC has now published an impact note and draft legislation.
Part 10 of the Finance Bill 2016, contains three new proposed criminal offences aimed at tackling tax evasion. The new offences criminalise failure to (1) give notice of liability to income or capital gains tax, (2) provide a return or (3) make an accurate return. These offences will be strict liability offences which means that it will not be necessary for the Crown to prove an intention to evade tax on the part of the taxpayer.