Alan Newman QC and James Kessler for the appellant in the second case.
Crime — Common law offence — Cheating public revenue — Offshore companies registered in Jersey — Concealment of central management and control in United Kingdom — Companies’ income deemed to be that of individual resident in United Kingdom — Shadow director failing to declare benefits provided by companies and to respond truthfully to questioning — Whether deeming provision affecting company’s liability to corporation tax — Whether infringement of right to peaceful possession of property — Whether shadow director liable to tax under Schedule E in respect of benefits in kind and accommodation — Whether violation of shadow director’s right to fair trial — Income and Corporation Taxes Act 1988 (c 1), ss. 19(1), 145(1)(8), 154(1), 167(1)(a), 168(2)(8), 739(2)1 — Human Rights Act 1998 (c 42), Sch 1, Pt I, art 6, Pt II, art 12