No good reason for delayed request for review

The taxpayer was a partnership intermediary in which Sky tennis commentator Barry Cowan was a member. In June 2021 HMRC stated that it considered Mr Cowan should be treated as an employee by Sky because the relationship was one of service. In November 2021 it issued determinations under regulation 80 of the Income Tax (PAYE) Regulations 2023 and notices under s 8 of Social Security and Contributions (Transfer of Functions) Act 1999 for the years 2014-15 to 2018-19.

The taxpayer’s representative responded by complaining on how the enquiry had been managed including that some of the correspondence from Sky was not disclosed to the taxpayer before the decision was made. In December HMRC invited the taxpayer to take up its offer of a review and on 17 January 2022 made a ‘without prejudice’ approach to the taxpayer to settle the dispute. On the basis that the...