R v K [2007] EWCA Crim 491, [2007] All ER (D) 138 (Mar)
Where a defendant fraudulently under-declares the takings of his business, thereby depriving the public revenue of income tax and VAT, he has obtained a pecuniary advantage as a result of criminal conduct within the meaning of the Proceeds of Crime Act 2002, sub-s 340(6). The unpaid tax represents a benefit under sub-s 340(3)(a).
