Regina v Sale [2013] EWCA Crim 1306; [2013] WLR (D) 304
“Where the defendant was the sole shareholder of a company for which he had secured commercial contracts by corruption, the assessment of the defendant’s criminal benefit for the purposes of a confiscation order could not be based on the turnover from the contracts because that would be disproportionate but should be restricted to the gross profit earned by the company together with any other pecuniary advantage which flowed from the corruption.”
WLR Daily, 25th July 2013
Source: www.iclr.co.uk