Thariq Mohammed, owner of the Happy Chippy, was originally assessed for £1.1m and handed a penalty of £998,420, totalling £2.1m in 2017, but due to more evidence coming to light settlement discussions were held and the assessment was reduced to £699,353 and the penalty to £515,522, totalling £1,214,875. This was in April 2017.

The First Tier Tribunal (FTT) was told that HMRC officer Bland first contacted Mohammed on 27 January 2014 opening a Code of Practice 9 (COP9) investigation as ‘HMRC suspected serious tax fraud had been committed’.

A contractual disclosure facility (CDF) was offered to Mohammed, but he did not respond to this offer.