There is no statutory definition of serious fraud. The only reference to ‘serious fraud’ in the tax legislation is contained in TMA 1970 s. 20C (1A):
’20C (1A) Without prejudice to the generality of the concept of serious fraud –
HMRC’s view of fraud is outlined in its instructions to inspectors:-
‘Fraud (in relation to the Revenue) includes, in its various forms, falsification with an intention to deceive and this may be present even as a mere conscious understatement in, or omission from, a return or accounts.
Thus, the active intention to deceive may, on the other hand, be so slight that the falsification differs little from that resulting from carelessness or negligence. On the other hand, falsification may be deliberately planned with the clear intention of deceiving and cheating the Revenue by, for example, the omission, manipulation or invention of figures, or other records.’