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No Accounting for Tax Avoidance
PREM SIKKA
Abstract
In the 2010–15 Parliaments, the UK House of Commons Committee of Public Accounts held
hearings and investigated some of the operations of the tax avoidance industry. Its reports
have been highly critical of the role of big accountancy firms in designing, marketing and
implementing tax avoidance schemes which have enabled their clients to avoid taxes. The
Committee’s recommendations set a reform agenda but drew a lukewarm response from the
government. An examination of the Committee’s reports provides an indication of the trajec-
tories of future debates and policies.
Keywords: tax avoidance, Public Accounts Committee, accountancy firms
INthe 2010 Parliament, under its Labour
chair Margaret Hodge, the UK House of
Commons Committee of Public Accounts
(hereafter the Public Accounts Committee or
PAC) achieved a high public profile.
Between 2010–11 and 2014–15 it produced
twenty reports on taxation, of which six are
substantially concerned with organised tax
avoidance and the tax avoidance industry.
1
This industry designs, markets and imple-
ments these schemes and is dominated by
the ‘big four’accountancy firms—Deloitte &
Touche, PricewaterhouseCoopers (PwC),
KPMG and Ernst & Young (E&Y). A com-
mon theme, summed up in the Committee’s
most recent report on Improving Tax Collec-
tion, is that the ‘big accountancy firms sell
tax advice to multinationals that involve con-
structing artificial tax arrangements that
serve only to help them avoid UK taxes’
(p. 10). The Committee recommended an
end to self-regulation of tax advisers.
A major reason for the PAC’s scrutiny of
the tax avoidance industry is that the reve-
nues lost through tax avoidance/evasion are
large enough to make a significant difference
to government finances. In its 2013–14
Annual Report and Accounts, the UK’s tax
authority, Her Majesty’s Revenue and Cus-
toms (HMRC), estimated the annual tax gap
—which consists of tax arrears, evasion and
avoidance—to be around £35 billion.
2
This
amount has persisted for nearly a decade
and includes tax evasion of £4.1 billion and
avoidance of £3.1 billion. Others estimate the
tax gap to be as much as £120 billion a year.
3
Successive UK governments have failed to
investigate the tax avoidance industry, and
this vacuum forms the background to the
PAC hearings and reports. The remainder of
this article focuses on the role of big accoun-
tancy firms in tax avoidance and the PAC’s
interventions to expose their practices and
demand change.
This paper consists of three further sec-
tions. The first section provides background
to the role of big accountancy firms in tax
avoidance, something which prompted the
PAC to hold its hearings. It also provides a
few examples of the tax avoidance schemes
crafted by these firms. The second section
provides some details of the PAC’s interven-
tion to expose the role of big accountancy
firms in organised tax avoidance. The third
section concludes with a brief discussion and
reflections on UK responses to the tax avoid-
ance industry.
The tax avoidance industry
The ‘big four’accountancy firms have a com-
bined annual global income (as per informa-
tion on their websites) of around £75 billion.
Some £25 billion of this comes from tax
advice, though the amounts attributed to UK
tax avoidance schemes are unknown. Their
UK arms second advisers to government
departments and have close links with leading
The Political Quarterly
©The Author 2015. The Political Quarterly ©The Political Quarterly Publishing Co. Ltd. 2015
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politicians. For example, former KPMG chair-
man Sir Michael Rake has acted as an adviser
to Prime Minister David Cameron.
4
In 2005,
an internal HMRC study concluded that the
UK arms of the ‘big four’firms were responsi-
ble for almost half of all known avoidance
schemes.
5
They were thought to be generating
around £1 billion in fees each year from ‘com-
mercial tax planning’and ‘artificial avoidance
schemes’.
The ‘big four’firms audit 96 per cent of
FTSE 250 companies,
6
which gives them easy
access to senior corporate executives; this, in
turn, is used as a vehicle for selling other
services, including tax avoidance. An illus-
tration is provided by the case of Iliffe News
and Media Ltd (INML), a highly profitable
group of local newspaper companies audited
by E&Y. The firm devised a tax avoidance
scheme under which existing newspaper
mastheads suddenly became new assets.
These were transferred to the parent com-
pany for a nominal sum and immediately
leased back to the subsidiaries for royalties.
Over a five-year period, the subsidiaries paid
royalties of £51.6 million. These intragroup
transactions did not result in transfer of cash
to an external party, but the subsidiaries
sought tax relief on the royalty payments.
The company’s board minutes noted that the
finance director ‘reported that [E&Y] had
confirmed that if the newspaper titles and/
or mastheads were registered as trade marks
in the ownership of [INML], it was possible
for the latter [i.e. INML] to charge the news-
paper companies a fee for the use of the for-
mer in a tax efficient manner that would
significantly lessen the transparency of
reported results. It was agreed to progress
this matter in consultation with [E&Y]’(par-
agraph 54 of Iliffe News and Media Ltd & Ors
v Revenue & Customs [2012] UKFTT 696 (TC)
(01 November 2012)).
The ‘big four’firms have a history of cre-
ating novel tax avoidance schemes.
7
For
example, E&Y devised avoidance schemes to
enable the directors of Phones 4u to avoid
UK National Insurance contributions (NIC)
by paying themselves in gold bars, fine wine
and platinum sponge. E&Y sold a scheme
involving intergroup loans and interest pay-
ments to its audit client Greene King, a lead-
ing pub retailer and brewer. The firm was to
receive part of the tax saved. Greene King
was unsuccessful in securing tax relief on an
interest payment of £21.3 million: the scheme
was thrown out by the First-Tier Tribunal in
its judgment in Greene King plc & Anor v
Revenue & Customs [2012] UKFTT 385 (TC)
(14/06/2012).
Deloitte & Touche designed a scheme for
Deutsche Bank to enable its UK staff to
avoid income tax and NIC on bonuses of
£92 million. The scheme operated through a
Cayman Islands entity and was declared to
be unlawful in the judgment in Deutsche
Bank Group Services (UK) Ltd v Revenue &
Customs [2011] UKFTT 66 (TC). The judge
said that the scheme ‘was created and coor-
dinated purely for tax avoidance purposes’
(para 112 of the judgment). Another Deloitte
scheme, in the case of Explainaway Limited v
HMRC [2012] UKUT 362 (TCC), was
designed to avoid the corporation tax that
would have arisen on the disposal of certain
shares. By following the steps designed by
Deloitte, its client company entered into a
series of complex paper transactions to gen-
erate a loss. The scheme was thrown out by
the First-Tier Tribunal and the Upper Tribu-
nal because there was no real loss.
A KPMG scheme to enable its audit client
to artificially generate a tax credit of £14 mil-
lion was thrown out by the tax tribunal in
the case of Peninsular & Oriental Steam Navi-
gation Company v Revenue & Customs [2013]
UKFTT 322 (TC) (29 May 2013). The scheme
involved a series of contrived transactions
between the UK and Australian subsidiaries
to boost tax credits on dividend income. The
judges said that the scheme was ‘all part of
an elaborate trick designed to exploit [tax
legislation].... P&O and its subsidiaries
played out a scripted game of charades’
(paragraph 69 of the judgment). In another
scheme, KPMG collaborated with Barclays
PLC to mass-market an avoidance scheme to
several corporations, including AIG, Micro-
soft, Prudential, Wachovia, Wells Fargo,
Bank of New York Mellon and Branch Bank-
ing & Trust (BB&T). The main objective was
to arbitrage the UK and US tax systems and
generate a series of foreign tax credits which
could then be offset against the US tax liabil-
ity of the companies. The scheme was
thrown out by the US courts and the judge
said that ‘the conduct of those persons from
BB&T, Barclays, KPMG... who were
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The Political Quarterly ©The Author 2015. The Political Quarterly ©The Political Quarterly Publishing Co. Ltd. 2015
involved in this and other transactions was
nothing short of reprehensible’(pp. 3–4of
Salem Financial Inc. v United States, No. 10-
192T (Ct. Fed. Cl. Sept. 20, 2013).
PwC is credited with developing Ireland
as a tax haven, and in particular refining a
scheme known as the Double Irish Dutch
Sandwich.
8
The scheme shifts profits from
one jurisdiction (e.g. the UK) to a low/no-
tax jurisdiction (e.g. Ireland, the Bahamas)
through royalty payments, intragroup pric-
ing techniques and complex corporate struc-
tures. Technology companies such as Apple,
Facebook, Google, Intel, LinkedIn and Micro-
soft are known to use the scheme to avoid
taxes in many countries. In May 2012, the
BBC’s Panorama programme showed how
PwC schemes enabled multinational corpora-
tions, such as GlaxoSmithKline and Northern
& Shell, to move profits to offshore tax
havens via Luxembourg.
9
The schemes
involved a variety of intergroup loans, con-
trived interest payments and transfer pricing
arrangements to reduce profits in the UK
and avoid corporate taxes. Another PwC
scheme enabled wealthy entrepreneurs to
avoid tax on the gains made on the sale of
investments and businesses. The Court of
Appeal declared it to be unlawful because
‘for capital gains purposes, there was no asset
and no disposal’(para 43, Schofield v HM
Revenue and Customs [2012] EWCA Civ 927).
The above is a brief glimpse of the
involvement of big accountancy firms in tax
avoidance. Despite strong court judgments
and extensive media coverage, successive
governments have failed to investigate the
tax avoidance industry. No accountancy firm
has ever been prosecuted, investigated or
fined for designing, marketing or implement-
ing tax avoidance schemes, even after the
courts have rejected them. In this vacuum,
the PAC held its hearings into the operations
of the tax avoidance industry.
Interventions by the Public
Accounts Committee
Some evidence of accountancy firms’com-
plicity in tax evidence was noted in the
PAC’s November 2012 hearings into the
management of HMRC and tax avoidance
schemes operated by Google, Starbucks and
Amazon (see note 1, Report 2012). All of
these companies are audited by the ‘big four’
firms and use a variety of accounting
techniques, such as royalty payments on
self-generated assets, transfer pricing and in-
tragroup interest payments to shift profits
from the UK to low/no-tax jurisdictions.
10
However, the audited accounts provide little
or no information about the tax avoidance
strategies used. The PAC followed up with a
hearing into the marketing of tax avoidance
schemes by specialist trade organisations
(note 1, Report 2013a). The PAC report was
critical of HMRC’s efforts in tackling organ-
ised tax avoidance, partly attributed to cuts
and lack of staff, and noted that there ‘are
no penalties for promoting avoidance
schemes, and businesses make substantial
sums of money from doing so’(p. 5).
In January 2013, the ‘big four’firms
became the subject of a hearing and their
senior partners responsible for UK tax opera-
tions were questioned by the PAC (note 1,
Report 2013b). Just before the hearing, the
Committee received evidence from a senior
former PwC employee stating that within
the firm, the policy was that it would sell a
tax avoidance scheme which had only a 25
per cent chance of withstanding a legal chal-
lenge—or, as the Committee chairman put it,
‘you are offering schemes to your clients—
knowingly marketing these schemes—where
you have judged there is a 75% risk of it
then being deemed unlawful’(p. Ev 4). The
other three firms admitted to selling schemes
that they considered to have only a 50 per
cent chance of being upheld in court. A
major tactic used by the firms was to deny
that they were engaged in tax avoidance and
insist that their practices were lawful, some-
thing which could only be disproved if
HMRC were to mount a costly legal chal-
lenge to most of their schemes. The firms
claimed that they had their own code of con-
duct which required them to act in an ethical
and responsible way, though the Committee
was highly sceptical of the claims and con-
tinuously reminded them that their practices
were unethical, if not unlawful.
Throughout the hearings, the ‘big four’
firms were generally on the defensive, and
cooperation with the PAC was grudging and
very scarce. Consider the case of Google, a
global technology corporation audited by
NOACCOUNTING FOR TAX AVOIDANCE 3
©The Author 2015. The Political Quarterly ©The Political Quarterly Publishing Co. Ltd. 2015 The Political Quarterly
E&Y, which is also its tax adviser. The com-
pany’s accounts always received a clean bill
of health even though they provided no
information about tax avoidance strategies.
Google was subject to PAC’s hearing in
2012. It used complex corporate structures
and intragroup pricing strategies to shift
profits to low/no-tax jurisdictions and avoid
corporate taxes. The chair of the PAC
directly asked an E&Y partner, ‘Did you
help them [Google] come up with a sort-of
curious structure, whereby their UK sales are
reported and claimed in Ireland, and then
the Irish company pays most of the turnover
and fees to an entity in Bermuda? Did you
help them with that?’The partner replied: ‘I
am not able to comment about the specifics’
(2013b Report, p. Ev 10). The firm would not
budge from this position.
The Committee was concerned about con-
flicts of interest arising out of the direct role
of accountancy firms in crafting legislation
and then using this inside knowledge to mar-
ket their taxation services. It noted that KPMG
seconded staff to advise the government on
the development of the ‘Patent Box’legislation
(see details of legislation at https://www.gov.
uk/corporation-tax-the-patent-box). The firm
then produced brochures which highlighted
its role in crafting tax laws and advised clients
that the ‘legislation is a business opportunity
to reduce UK tax and that KPMG can help
clients...’(2013b Report, p. 10).
The Committee argued that organised tax
avoidance could be countered through
greater corporate disclosures, but the firms
responded that this could not be achieved by
requiring companies to publicly file their tax
returns alongside their financial accounts, as
tax returns are too long and complex to offer
transparency. The PAC was supportive of
country-by-country reporting, which would
require multinational corporations to publish
a report showing their turnover, profit and
tax for each country of their operations. This
could draw attention to artificial shifting of
profits. For example, a multinational may be
reporting high profits in a jurisdiction even
though it has a skeleton staff and little eco-
nomic activity. Such mismatches can act as
red flags, but the ‘big four’firms were not in
favour of such reporting.
Fresh whistleblower information and
media reports drew attention to gaps in
Google’s previous testimony to the Com-
mittee.
11
These reports explained how Go-
ogle routes its UK business through Ireland
and Bermuda, with the result that taxes vir-
tually disappear. For the period 2006–11,
Google’s UK operations generated revenues
of $18 billion (£11.5 billion), but the com-
pany paid just $16 million (£10 million) in
corporate taxes (i.e. less than £1 for every
£1,000 of revenue). So, Google and E&Y’s
tax partners were recalled by the Commit-
tee (note 1: Report 2013c). E&Y were
admonished for being economical with
information, but the firm cited client confi-
dentiality and refused to divulge any fur-
ther details.
A further opportunity to question accoun-
tancy firms arose from what became known
as the Luxembourg leaks. A former PwC
employee based in Luxembourg leaked some
28,000 pages of letters, tax agreements and
returns, which received extensive media cov-
erage and are publicly available. The pub-
licly available documents (see http://www.
icij.org/project/luxembourg-leaks) show that
PwC designed tax avoidance schemes for
major corporations such as Abbott Laborato-
ries, Accenture, Amazon, Aviva, Axa, Bur-
berry, Citigroup, Deutsche Bank, Dyson,
Disney, Eon, Heinz, HSBC, IKEA, Koch, Pep-
si, Procter and Gamble, Shire, Skype, Taylor
Wimpey, Vodafone, Wolseley and many
more. About eighty of the companies are
headquartered in the UK. The essence of the
schemes was to shift profits to low/no-tax
jurisdictions through complex corporate
structures and a variety of intergroup royal-
ties, prices and loans. The details of the
schemes are on PwC headed paper and
signed off by a partner. PwC also negotiated
tax rulings for companies with the Luxem-
bourg tax authorities.
In view of these very public disclosures,
the PAC reconvened on 8 December 2014
and recalled a PwC tax partner, who was
accompanied by the Head of Tax at Shire
Pharmaceuticals, a company incorporated in
Jersey but domiciled in Ireland for tax pur-
poses. The Committee (Report 2015a) chas-
tised PwC for promoting avoidance schemes
on an ‘industrial scale’. PwC’s constant line
of defence was that ‘we are not in the busi-
ness of selling schemes’and ‘we do not
mass-market tax products, we do not pro-
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The Political Quarterly ©The Author 2015. The Political Quarterly ©The Political Quarterly Publishing Co. Ltd. 2015
duce tax products, we do not promote tax
products’(p. 5). The firm claimed that it
offered tailored advice to meet the needs of
individual clients and was thus not
‘mass-marketing’anything. Once again, the
firm defended its practices by appealing to its
Code of Conduct, the Committee concluding
that the ‘code is not fit for purpose’(p. 6).
PwC invoked ‘confidentiality’arguments and
did not provide any additional information to
the Committee. It also refused to discuss any
aspect of any leaked documents.
The PAC reports do not touch upon the
possibility of the wholesale reform of the
current system of corporate taxation, but do
contain a number of proposals for reforms.
The committee recommended that compa-
nies should publish more information on
their tax affairs. It argued that HMRC’s rela-
tionship with large accountancy firms is too
cosy, and that HMRC was simply not robust
enough in challenging the advice given by
accountancy firms to multinational corpora-
tions. It was concerned that staff from the
‘big four’firms are seconded to HM Trea-
sury to design tax laws, and the firms then
go on to advise their clients on how to use
those laws to avoid tax. The PAC wanted a
ban on such practices. The Committee
rejected the current system of self-regulation
applied to accountancy firms and called for
a new system of regulation, urging the gov-
ernment to implement a code of conduct for
all tax practitioners. Its final report (Report
2015b), issued just before the dissolution of
parliament for the May 2015 general election,
urged the next government to introduce new
offences to penalise those involved in advis-
ing companies and individuals to avoid or
evade taxes.
Summary and discussion
The UK has a well-established tax avoidance
industry which is eroding the tax base and
enabling those who can afford it to hire
accountants to avoid taxes. Despite consider-
able media coverage, there have been no
government-led investigations. The PAC
hearings did not examine any of the wit-
nesses on oath or subpoena crucial docu-
ments. In the absence of any legal
compulsions, the ‘big four’firms were
economical with information and did not
provide any new information to the Com-
mittee. The firms opposed any suggestions
for reforms, such as those relating to greater
corporate disclosures and the ending of self-
regulation. The government’s response to the
PAC recommendations was couched in
appropriate political language, but it claimed
that HMRC was already taking robust action
against tax avoidance. The government was
not keen on a new regulatory system for the
tax avoidance industry and did not support
the call for a statutory code of conduct as it
believed that the existing voluntary code of
ethics promulgated by the Institute of Char-
tered Accountants in England and Wales
was adequate, even though it has no statu-
tory underpinning and does not apply to
non-accountants (e.g. lawyers).
12
It is worth
bearing in mind that no accountancy firm
has ever been disciplined by the professional
bodies for designing, marketing or imple-
menting tax avoidance schemes, even after
they have been declared unlawful by the
courts.
The Committee (Report 2013b) objected to
tax avoiders and their advisers receiving
public contracts, and this coincided with the
government’s announcement that it would
ban such parties from securing taxpayer-
funded contracts. However, the eventual
rules,
13
introduced in April 2013, only apply
to central government (not local authority)
contracts above £5 million and only the par-
ties taking part in failed avoidance schemes
can be disqualified. The rules only apply to
non-compliance after 1 April 2013. With a
backlog of 27,246 cases
14
awaiting hearing by
tax tribunals and some cases lasting up to a
decade, the prospect of anyone being banned
is miniscule. At the time of writing (April
2015), no one engaged in tax avoidance had
been banned from securing taxpayer-funded
contracts.
The PAC hearings have not been followed
up by HM Treasury, the Department of Jus-
tice or any other government agency. This is
in marked contrast to the US, where Senate
Committee hearings have been followed up
by the Department of Justice, leading to fines
on the ‘big four’accountancy firms and
prison sentences for some of their senior per-
sonnel.
15
For example, in 2005, KPMG was
fined $456 million for facilitating tax evasion
and subsequently a number of its senior per-
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©The Author 2015. The Political Quarterly ©The Political Quarterly Publishing Co. Ltd. 2015 The Political Quarterly
sonnel received prison sentences; in 2013,
Ernst & Young paid a fine of $123 million to
avoid a criminal prosecution for alleged tax
frauds and a number of its personnel also
received prison sentences.
16
Without a major
shift in UK government policies on the regu-
lation of the tax avoidance industry, there is
little chance of checking the massive leakage
of tax revenues, though the 2015 election
manifestos of all major parties flagged an
assault on organised avoidance. Pressures
for change are likely to arise from continuing
media exposure and further inquiries by the
PAC, especially as the Committee’s remit to
scrutinise public expenditure and accounts
requires it to examine the efficiency of
HMRC in collecting taxes. The PAC tem-
plate, established during the 2010–15 parlia-
ment, has focused on leakages of tax
revenues, tax avoidance and the tax avoid-
ance industry, and is unlikely to be aban-
doned for the foreseeable future. In their
election manifestos, all major political parties
promised to reduce government borrowing
and increase public expenditure on matters
such as the National Health Service and
school education. Failure to deliver at least
some of these promises is likely to alienate
the electorate and may well persuade the
government to mount a serious assault on
the tax avoidance industry.
Acknowledgement
I am very grateful to Meg Russell for her
advice and patience.
Notes
1 UK House of Commons Committee of Public
Accounts, HM Revenue & Customs: Annual
Report and Accounts 2011–12, London, The Sta-
tionery Office, 2012; Tax Avoidance: Tackling
Marketed Avoidance schemes, London, The Sta-
tionery Office, 2013a; Tax Avoidance: The Role of
Large Accountancy Firms, London, The Station-
ery Office, 2013b; Tax Avoidance–Google, Lon-
don, The Stationery Office, 2013c; Tax
Avoidance: The Role of Large Accountancy Firms
(follow–up), London, The Stationery Office,
2015a; Improving Tax Collection, London, The
Stationery Office, 2015b.
2 There are numerous debates about the mean-
ings of ‘evasion’and ‘avoidance’. In general,
‘evasion’is unlawful and ‘avoidance’is fre-
quently equated with differences of opinion
about the meaning of legislation. Some people
refer to ‘avoidance’as the grey zone.
3 R. Murphy, The Tax Gap £119.4bn, London,
Public and Commercial Services Union, 2014.
4 Daily Mail,‘One in four in David Cameron’s
Business Advisory Group avoids tax’, 28 April
2012, http://www.thisismoney.co.uk/money/
news/article-2136598/One-in-David-Cameron-
advice-group-avoids-tax.html (accessed 22
March 2015).
5 The Guardian,‘Gilt-edged profits for profes-
sion’s“big four”’, 7 February 2009, http://
www.theguardian.com/business/2009/feb/07/
tax-gap-avoidance-schemes (accessed 24 March
2015).
6 Financial Reporting Council, Key Facts and
Trends in the Accountancy Profession, London,
FRC, 2014.
7 A. Mitchell and P. Sikka, The Pin-Stripe Mafia:
How Accountancy Firms Destroy Societies, Basil-
don, Association for Accountancy & Business
Affairs, 2011.
8 Bloomberg, ‘Man making Ireland tax avoid-
ance hub proves local hero’, 28 October 2013,
http://www.bloomberg.com/news/2013-10-28/
man-making-ireland-tax-avoidance-hub-glob-
ally-proves-local-hero.html (accessed 22 March
2015).
9 BBC News, ‘Major UK companies cut secret
tax deals in Luxembourg’, 11 May 2012,
http://www.bbc.co.uk/news/business-
17993945 (accessed 22 March 2015).
10 For further details see P. Sikka and H. Will-
mott, ‘The dark side of transfer pricing: Its role
in tax avoidance and wealth retentiveness,
Critical Perspectives on Accounting, vol. 21, no.
4, 2010, pp. 342–56.
11 Reuters, ‘Special report –How Google UK
clouds its tax liabilities’, 1 May 2013, http://
uk.reuters.com/article/2013/05/01/uk-tax-uk-
google-specialreport-idUKBRE94005R20130501
(accessed 22 March 2015).
12 HM Treasury, Government Responses on the
Twenty Fifth to the Twenty Ninth, the Thirty First
to the Thirty Second, the Thirty Fourth, the Thirty
Sixth, and the Thirty Eighth to the Fortieth reports
from the Committee of Public Accounts: Session
2014-15, London, HM Treasury, 2015, https://
www.gov.uk/government/uploads/system/
uploads/attachment_data/file/414663/48464_
Cm_9033_Treasury_Minutes_accessible.pdf
(accessed 22 March 2015).
13 Cabinet Office, ‘New rules use government
buying power against tax avoidance’, 14 Feb-
ruary 2013, https://www.gov.uk/govern-
ment/news/new-rules-use-government-buying-
power-against-tax-avoidance (accessed 22 March
2015).
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14 Financial Times, Appeals at UK tax court leap
by a third, 23 November 2014, http://www.
ft.com/cms/s/0/551f6a36-71b1-11e4-9048-00144
feabdc0.html#axzz3ZScprwO7 (accessed 22
March 2015).
15 US Senate Permanent Subcommittee on Inves-
tigations, US Tax Shelter Industry: The Role of
Accountants, Lawyers, And Financial Professionals
–Four KPMG Case Studies: FLIP, OPIS, BLIPS
and SC2, Washington DC, USGPO, 2003; The
Role of Professional Firms in the US Tax Shelter
Industry, Washington DC, USGPO, 2005.
16 US Department of Justice press releases:
‘KPMG to Pay $456 Million for criminal viola-
tions in relation to largest-ever tax shelter
fraud case’, 29 August 2005, http://www.
justice.gov/archive/opa/pr/2005/August/05_ag_
433.html (accessed 22 March 2015); ‘Manhattan
U.S. attorney announces agreement with Ernst
& Young LLP to pay $123 million to resolve
federal tax shelter fraud investigation’,1March
2013, http://www.justice.gov/usao/nys/press-
releases/March13/EYNPAPR.php (accessed 24
March 2015).
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