Late appeal allowed:C Horder v HMRC[2023] UKUT 106 (TCC) (11 May 2023) is an unfortunate case in which an unpaid director of a company who accepted that he was a ‘patsy’ for the company’s shadow director found himself liable to provide HMRC with security for PAYE and NIC payments and subject to a criminal charge for failing to do so. The director made an application for a late appeal against the notice requiring security. The approach of the tribunals to such applications is well established and the UT had little difficulty in concluding that the FTT’s decision not to allow it contained no errors and so dismissed the appeal. There are a couple of points of wider interest in the decision. The first is that the FTT had heard both the application for the late appeal and the substantive appeal at the same time. Because...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Late appeal allowed:C Horder v HMRC[2023] UKUT 106 (TCC) (11 May 2023) is an unfortunate case in which an unpaid director of a company who accepted that he was a ‘patsy’ for the company’s shadow director found himself liable to provide HMRC with security for PAYE and NIC payments and subject to a criminal charge for failing to do so. The director made an application for a late appeal against the notice requiring security. The approach of the tribunals to such applications is well established and the UT had little difficulty in concluding that the FTT’s decision not to allow it contained no errors and so dismissed the appeal. There are a couple of points of wider interest in the decision. The first is that the FTT had heard both the application for the late appeal and the substantive appeal at the same time. Because...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
