Updated 15/09/25: HMRC confirms it has secured one charging decision
On 11 September 2025, HMRC published details of its corporate criminal offence investigations up to and including 30 June 2025, confirming that it has secured one charging decision.
It has been reported that the firm appeared at Manchester Crown Court on 7 August 2025, along with six individuals, including a former director of the firm. The charges relate to cheating the public revenue and money laundering. If the reports are correct, this will be the first prosecution brought under the corporate criminal offence (CCO) rules (s45, Criminal Finance Act 2017).
It is important that firms are aware of their responsibilities and have reasonable policies and procedures in place to prevent the facilitation of tax evasion. An earlier article from ICAEW provides more information on the CCO and explains what organisations need to be thinking about. The firm named in media reports is not an ICAEW-supervised/regulated firm.
HMRC has been criticised in the past for its failure to bring any prosecutions under this legislation. In the run-up to the 2024 general election, the Labour Party highlighted the lack of CCO prosecutions. Referring to experts views on HMRC’s powers to carry out criminal investigations, the Labour Party commented that custodial sentences could contribute to providing a “strong deterrent effect in long-standing and growing areas of tax non-compliance”.
Since 2020, HMRC has published details of its CCO activities. The latest figures up to 31 December 2024 are summarised below:
| As at | Number of live investigations | Number of live opportunities under review | Number of opportunities reviewed and rejected to date |
|---|---|---|---|
| 31 December 2024 | 11 | 28 | 114 |
| 30 June 2024 | 11 | 28 | 101 |
| 1 January 2024 | 11 | 24 | 94 |
| 30 June 2023 | 9 | 25 | 83 |
| 1 January 2023 | 9 | 26 | 77 |
| 13 May 2022 | 7 | 21 | 69 |
| 27 May 2021 | 14 | 14 | 40 |
| 13 October 2020 | 13 | 18 | 33 |
| 31 July 2020 | 10 | 22 | 30 |
| 31 December 2019 | 9 | 21 |
The trial has been scheduled for September 2027, by which time it will have been 10 years since the legislation was introduced.
Tax policy update
HM Treasury will be attending ICAEW's Annual Conference 2025 with a session discussing tax policy and economic growth in the weeks ahead of the Budget.
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