Revenue & Customs Commissioners v Total Network SL

In the tort of unlawful means conspiracy the 'unlawful means' need not constitute a tort actionable by the claimant; conduct that is criminal (here the common law offence of cheating the public revenue) and is aimed at the claimant can suffice — but the VAT statutory code being exhaustive, no common-law damages claim lies to recover VAT from a non-taxable person.