TC09663 - [2025] UKFTT 01250 (TC)

On 11 March 2022, HMRC issued the Determination.

On 21 March 2022, a formal request for a statutory review of the decision was received and the postponement of tax due of £133,615.60 was actioned on 25 March 2022.

On 14 April 2022, the Appellant appealed to HMRC.

On 13 June 2022, the Appellant’s solicitors confirmed that their only dispute was in relation to Condition 1 of Part 2 of the PAYE Regulations.

On 17 June 2022, HMRC issued their view of the matter letter.

On 23 June 2022, a letter was issued to the Appellant, upholding the decision to issue the Determination on the basis that the Agency legislation applied.

On 16 September 2022, the Appellant notified the appeal to the First-tier Tribunal (‘FtT’).

On 20 January 2023, HMRC served their Statement of Case.

On 19 April 2024, HMRC wrote to the FtT and the Appellant stating, inter alia, that the Grounds of Appeal do not make any reference to best judgement, or indicate an intention to challenge HMRC’s use of best judgement under reg. 80(2) of the PAYE Regulations in respect of the Determination.

On 29 April 2024, HMRC requested that the Appellant provide amended Grounds of Appeal. The Appellant did not amend its Grounds of Appeal.