TC09663 - [2025] UKFTT 01250 (TC)

Regulation 80 provides that:

“80.

Determination of unpaid tax and appeal against determination

(1)

This regulation applies if it appears to HMRC that there may be tax payable for a tax year ... by an employer which has neither been –

(a)

paid to the Inland Revenue,

[...]

(2)

HMRC may determine the amount of that tax to the best of their judgment, and serve notice of their determination on the employer.

[...]

(5)

A determination under this regulation is subject to Parts 4, 5, 5A, and 6 of TMA (assessment, appeals, collection and recovery) as if –

(a)

the determination were an assessment, and

(b)

the amount of tax determined were income tax charged on the employer, and those parts of that Act apply accordingly with any necessary modifications.”