On 30th June, HMRC released figures for the number of live corporate criminal offence (CCO) investigations. The report confirms that labour provision remains a high-risk area.
HMRC confirmed that the reviews have led HMRC to find other tax and regulatory offences to pursue. This fits with HMRC's historic stance of finding civil enforcement easier than prosecution.
HMRC's and the courts' new stance is now being applied with hindsight against the backdrop of the complex interplay between different pieces of tax legislation. These include IR35, agency-worker tax rules, offshore employer's rules, and managed-service-company legislation to produce significant tax risks.
In March, Stacey Mills-Kelly, assistant director, and head of strategies at HMRC Fraud Investigation Service, confirmed that HMRC activity to prevent tax evasion in labour supply chains have started.