CRC v Cozens and others, Chancery Division
HMRC believed the taxpayer was involved with a large-scale fraud. The department applied successfully for a worldwide freezing order against him.
The taxpayer said he had not known a fraud was taking place and the freezing order should be barred under FA 1994, s 12(4)(b). The Chancery Division judge ruled the order should continue because:
- HMRC had a good arguable case for the order to continue;
- any administrative failures on the part of the Revenue were insufficient grounds to discharge the order;
- there was a danger that the taxpayer would otherwise put his assets beyond the reach of HMRC; and
- there was no evidence of serious prejudice to the taxpayer if the order continued.
