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December's round up of the latest tax investigation news and cases:
Following bankruptcy last year, Frankie Dettori's personal services company is unable to pay a £765,000 tax bill due to insufficient funds.
The latest statement of affairs from the liquidators of Dettori's personal services company, Frankie Dettori Limited, showed "the company had two unsecured creditors with debts totalling £771,933."
The update from liquidators, Forvis Mazars, showed Dettori's company owes HMRC £765,542 for unpaid PAYE and national insurance contributions (NICs). In addition, a further £6,391 is owed to other creditors.
However, Dettori does not have the funds to settle the bills, the report stated: "Assuming that realisations and expenses are as anticipated, it is not expected that there will be a return to unsecured creditors due to insufficient funds."
The report said it had "identified several lines of enquiry which require further review."
The 55-year-old jockey declared bankruptcy in March 2025, citing tax bills and a dispute with HMRC as the main reason.
Dettori had been involved in a long-running dispute with HMRC over the use of a tax avoidance scheme, where he failed to keep his anonymity at a tax tribunal.
In a statement released at the time, Dettori said: "I am saddened and embarrassed by this outcome and would advise others to take a stronger rein over their financial matters."
Dettori's company was incorporated in May 2019 and placed into voluntary liquidation in October 2024. The last accounts for year ended 30 September 2023 were filed in May 2024.
The liquidators also said "HMRC have raised significant concerns that the company and its associated company, Newmarket Activities Limited, have been utilised for the purpose of tax avoidance."
Forvis Mazars is also the liquidator for Newmarket Activities, which owes £765,774 to HMRC for unpaid PAYE and NICs, and "it is not expected that there will be a return to unsecured creditors due to insufficient funds."
Dettori retired from UK racing in 2023 after a 35-year career when he was British flat racing champion jockey three times and was given an MBE for his contributions to racing. The veteran jockey recently completed a farewell tour in South America, although he is expected to completely retire from the sport this year according to the Racing Post.
The case highlights the serious financial and reputational consequences that can arise from tax avoidance schemes, particularly for high-profile individuals operating through personal service companies. With HMRC raising concerns about the utilization of both Frankie Dettori Limited and Newmarket Activities Limited for tax avoidance purposes, the situation underscores the risks associated with such arrangements and the potential for significant unpaid tax liabilities that may ultimately prove unrecoverable through liquidation proceedings.
US tech giant Amazon reported revenue of £29 billion in the UK in 2024, paying a total tax bill of £1 billion, up 7% on the previous year.
The total tax bill was £1 billion in 2024, up from £932 million the previous year, but Amazon was keen to stress that it paid a combined "taxes borne and collected" figure of £5.8 billion, up from £4.3 billion in 2023.
The total borne figure includes employment taxes, business rates, VAT, plastic packaging tax and stamp duty land tax, along with corporation tax, in a 34% increase year on year.
In the update, Amazon said it was "a top 10 taxpayer in the UK." As a "result of business activities in the UK," the multinational paid £500 million in employer taxes in 2024, primarily made up of employer national insurance contributions (NICs) and £175 million in business rates, which it said was partly the result of a growing physical stores presence.
The total worldwide workforce is now more than 1.5 million people, including 75,000 staff in the UK. This includes software development, product management, and engineering, as well as jobs in fulfilment centres, sort centres, and delivery stations.
Amazon stressed its commitment to invest £40 billion in the UK across 2025-27, saying it intends to "create thousands of new permanent jobs," including over 2,000 positions outside of London and the Southeast.
In total, Amazon also spent £1.6 billion on capital investment in 2024 for the latest robotics technology.
Amazon said the investment includes building four new fulfilment centres and new delivery stations nationwide, as well as upgrading and expanding its existing network of over 100 operations buildings.
John Boumphrey, UK country manager at Amazon, said: "For more than 25 years, we have been making a significant economic impact across the nations and regions of the UK. With our commitment towards job creation, innovation and helping small businesses to export, we believe in being a force for good in the lives of our customers and also the communities where we operate."
The substantial increase in Amazon's tax contributions reflects both the company's continued growth in the UK market and its expanding physical infrastructure. The 34% year-on-year increase in total taxes borne and collected demonstrates the company's significant role in UK tax revenues, while the planned £40 billion investment signals continued commitment to the British market through 2027.
The expansion of Amazon's UK operations, evidenced by growing employment numbers and physical presence, contributes to both direct tax payments and indirect economic benefits through job creation and infrastructure development across multiple regions of the country.
The Court of Appeal has ruled for HMRC in the latest round of the long-running Medpro case over the right to bring an appeal out of time over £1.06 million in penalties for disputed VAT, determining that Martland guidance is "appropriate."
HMRC was at the Court of Appeal in a fast-tracked case heard in late December to appeal the Upper Tribunal decision in Medpro Healthcare Ltd v R & C Commrs [2025] BVC 510, over the right to file a late appeal.
It all related back to an earlier decision at the First Tier Tribunal (FTT) when it refused a late appeal by Medpro Health Care Ltd and Kalvinder Ruprai, a director of Medpro. It then went to the Upper Tribunal (UT), which ruled in favour of Medpro.
The Medpro case concerns a tax dispute with HMRC dating from 2019 over VAT, and the validity of a number of HMRC penalty notices, including a personal liability notice (PLN), totalling £1,063,236, issued in 2022.
The latest round at the Court of Appeal centered around whether the First Tier Tribunal (FTT) can "exercise its statutory discretionary power to extend time for appeal."
Much of the argument centered on Martland v HMRC [2018], which set out the Upper Tribunal position on "the correct approach when the FTT is considering an application to appeal out of time," the ruling stated.
At the one-day hearing, Medpro argued that "if the Upper Tribunal is entitled to give guidance to the FTT, the guidance in Martland is indeed flawed."
Meanwhile, HMRC's argument did not question Martland validity, but focused on "whether it is permissible for the Upper Tribunal to formulate guidelines for the exercise of that discretion by the First Tier Tribunal."
After hearing arguments, in a unanimous decision the Court of Appeal ruled the Martland guidance was "appropriate" and sent the case back to the FTT to proceed.
In the ruling, Lord Justice Lewison stated: "In my judgment, if the UT is entitled to give guidance on the exercise of a statutory discretion (which, for the reasons I have given I consider that they are), then the UT in this case was correct in deciding that the Martland guidance, as amplified in Katib, was entirely appropriate."
In addition, LJ Lewison stressed: "Even if there were any doubt about the guidance, it is not for this court to interfere unless the guidance is wrong in law. I would allow the appeal, and reject the point raised in the respondent's notice. The Martland guidance (as amplified by Katib) is appropriate."
An HMRC spokesperson said: "We welcome the Court of Appeal's decision, which provides clarity on how late appeals should be handled."
This Court of Appeal ruling establishes important precedent regarding the Upper Tribunal's authority to provide guidance on late appeals to the First Tier Tribunal. By affirming the Martland guidance framework, the decision provides clarity for future cases where taxpayers seek to file appeals beyond statutory deadlines, reinforcing the structured approach that tribunals must follow when exercising discretion to extend time limits.
The case now returns to the First Tier Tribunal to be heard on its merits, with the procedural framework for considering the late appeal firmly established by the higher courts.
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