UT/2023/000126 - [2025] UKUT 00145 (TCC)

Case Number: UT/2023/000126

Rolls Building, London

Income Tax - discovery assessments and penalties imposed by National Crime Agency (“NCA”) adopting Revenue functions – whether FTT erred in not requiring NCA to meet a burden of showing loss of tax arising from trade of money laundering – effect of section 319 POCA 2005 – whether FTT entitled to find that there was a loss of tax – whether FTT entitled to find that the Second Appellant brought about a loss of tax deliberately – appeal dismissed

Judgment date: 9 May 2025

Before

UPPER TRIBUNAL JUDGE SWAMI RAGHAVAN

UPPER TRIBUAL JUDGE JONATHAN CANNAN

Between

MOHAMMED BUTT

MAHFOOZ BEGUM

Appellants

and

NATIONAL CRIME AGENCY

Respondent

Representation:

For the Appellants: Laurent Sykes KC and Ben Blades, Counsel, instructed by Aliant Law

For the Respondents: Sarah Black, Counsel, instructed by the National Crime Agency

DECISION