Do you remember the fallout from the Panama Papers? Do you remember HMRC’s response pledging to prosecute 100 wealthy individuals and corporates per year by 2020? Do you remember the new corporate offence of failure to prevent the facilitation of tax evasion announced with much fanfare as part of the Criminal Finances Act 2017?

With Brexit dominating both the headlines and HMRC’s limited resources over the last two years, it’s easy to forget the extent of the public and political condemnation concerning businesses and high net worth individuals ‘getting away’ with tax fraud. The furore led to a raft of new legislation and measures being introduced which aimed to hold corporates to account.

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