Requirement to provide security

HMRC required the taxpayer to provide security for PAYE and National Insurance because it had a history of underpayments. Further it had not complied with a time-to-pay arrangement. HMRC warned the company that it would have to provide security if it failed to pay the outstanding tax debts.

The company appealed saying it was a growing business with a good record of paying tax so it did not present a risk. Further it was trying to clear the balance owed to HMRC and the security required would cause financial problems.

The First-tier Tribunal said the company had provided no evidence of its growth or payment record. But it was clear that it had not kept up with PAYE payments. In effect the taxpayer had stated this itself by mentioning the outstanding sums due.

On the difficulties caused by paying the security the tribunal noted that ...