[2025] UKUT 00278 (TCC)

Of the Airedale claims in these proceedings, the only claim for which the power to recover issue is relevant is the claim for 2008/09. For that year HMRC issued a Regulation 80 determination in the sum of £768,070 specifying four named individuals. The PAYE settlement figure for those individuals, for that year, came to a total of £931,548.75, referencing contributions under two schemes, a Montpelier BBT scheme and an EFRBS scheme. The Regulation 80 determination figure was capable of being uplifted, on the basis set out above, to the PAYE settlement figure.