Alan Newman Q.C. and James Kessler (assigned by the Registrar of Criminal Appeals) for the second appellant.
Crime — Common law offence — Cheating public revenue — Offshore companies registered in Jersey — Concealment of central management and control in United Kingdom — Shadow director failing to declare benefits provided by companies — Companies’ income deemed to be that of individual resident in United Kingdom — Whether deeming provision affecting company’s liability to corporation tax — Whether shadow director liable to tax under Schedule E in respect of benefits in kind and accommodation — Whether actual or potential loss to revenue — Income and Corporation Taxes Act 1988 (c. 1), ss. 19(1), 145(1)(8), 154(1), 167(1)(a), 168(2)(8), 739(2), 831(1)1