[2013] EWCA Crim 1262
Where a taxpayer cheated the Revenue by falsely representing the turnover of a business, he obtained a pecuniary advantage and was taken to have obtained a benefit equal to tax due on the undeclared turnover. However, the "criminal property", as defined by the Proceeds of Crime Act 2002 s.340, was the entirety of the undeclared turnover, not merely the tax due.
CA (Crim Div) (Elias LJ, Mackay J, Judge Ford QC (Recorder of Bristol) )
18/07/2013