Partner Chris Roberts has provided comment in eprivateclient and Business & Accountancy Daily on the UK government’s proposals to introduce a new criminal offence for making reckless untrue statements or declarations in direct tax.

Providing clarity on the new proposal, Chris said: “This government consultation frames the proposal as plugging a gap in the law, pointing out that any new law would apply to direct tax, whereas the existing offence currently only applies to indirect tax.”

Highlighting the broader implications of the proposed offence, he commented: “But it continues the trend of seeking to expand the scope of the criminal law. As the consultation notes, it is already an offence to fraudulently evade tax, whether direct tax or indirect tax. It is not clear how the new offence would enable HMRC to take action where it could not already.”

“The new offence would require HMRC to show any defendant had made statements which they knew to be untrue, or that they submitted incorrect documents knowingly or recklessly. These are all difficult elements to prove.”

He concluded: “Proposing this new law may be logical, but whether it will be effective is another story.”

Chris’ comments were published in eprivateclient and Business & Accountancy Daily, 25 June 2026.