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It might be thought that taxation in England and Wales is regulated entirely by statute. Numerous provisions govern not only the charge rate and collection of tax from the law-abiding taxpayer but also what should happen in cases of non-compliance. Specific provisions criminalise particular types of conduct regulate the investigation of tax evasion and state the penalties to be imposed.
Surprisingly alongside this purpose-built criminal procedure there exists an offence that rests largely on a definition provided not by parliament but by the courts and commentators of the seventeenth and eighteenth centuries: the offence of ‘cheating the public revenue’.
A wide definition
It is an offence at common law to defraud or ‘cheat’ the general public (R v Hudson [1956] 2 QB 252). The offence was preserved by the Theft Act 1968 s 32(1)(a) which abolished the offence of cheating...
