Mohammed Butt and Another v The National Crime Agency [2025] UKUT 00145 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Raghavan and Judge Cannan on 09 May 2025
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Income Tax - discovery assessments and penalties imposed by National Crime Agency (“NCA”) adopting Revenue functions – whether FTT erred in not requiring NCA to meet a burden of showing loss of tax arising from trade of money laundering – effect of section 319 POCA 2005 – whether FTT entitled to find that there was a loss of tax – whether FTT entitled to find that the Second Appellant brought about a loss of tax deliberately – appeal dismissed