EDN (92/15)

No. 10,558

Decision given 27 May 1993.

Civil penalties – Tax evasion involving dishonesty – Underdeclaration of output tax – Standard of proof – Weight of evidence in civil case in Scotland affected by gravity of allegations – Test of dishonesty – Finance Act 1985, s. 13.

  The issue was whether the appellants had acted dishonestly in failing to declare output tax on the sale of milk quotas. This involved consideration of the nature of the standard of proof in Scotland in cases involving civil penalties where dishonesty was alleged.

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