Determinations and deliberate failure by the taxpayer
In Spring Salmon & Seafood v HMRC [2014] UKFTT 887 (11 September 2014) the FTT found that determinations issued by HMRC were valid.
Spring Salmon & Seafood carried on business as suppliers distributors and processors of seafood. Mr Thomas was its director. He also carried on a business in partnership with his brother as consultants and seafood dealers.
The main issue was the liability if any of the company to pay PAYE and NIC in respect of a £900 000 bonus to Mr Thomas and his brother and wages and salaries of £178 230. The FTT had to decide whether the monies had been paid by the company to the individuals whether HMRC’s determinations were time-barred and whether an alleged 2007 agreement barred HMRC from pursuing the liabilities.
The FTT observed that the company’s cessation accounts referred to...
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Determinations and deliberate failure by the taxpayer
In Spring Salmon & Seafood v HMRC [2014] UKFTT 887 (11 September 2014) the FTT found that determinations issued by HMRC were valid.
Spring Salmon & Seafood carried on business as suppliers distributors and processors of seafood. Mr Thomas was its director. He also carried on a business in partnership with his brother as consultants and seafood dealers.
The main issue was the liability if any of the company to pay PAYE and NIC in respect of a £900 000 bonus to Mr Thomas and his brother and wages and salaries of £178 230. The FTT had to decide whether the monies had been paid by the company to the individuals whether HMRC’s determinations were time-barred and whether an alleged 2007 agreement barred HMRC from pursuing the liabilities.
The FTT observed that the company’s cessation accounts referred to...
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