Statutory time limits must be respected

The taxpayer was appointed as director of PLL which operated a car park to help restructure the company after the accrual of a substantial debt by its founding shareholder. However PLL’s problems continued and HMRC sent it a security warning because it failed to pay the PAYE and National Insurance due. The taxpayer set up a time-to-pay arrangement but the company fell behind with the payments.

As a result HMRC issued PAYE National Insurance and VAT notices of requirement on PLL and the taxpayer as director of PLL. Both the company and the taxpayer made late appeals against the notices.

The company went into administration in August 2024 and joint administrators were appointed. They subsequently withdrew the company’s appeals.

The First-tier Tribunal noted the delay in the taxpayer submitting his appeal was seven months which was ‘serious and significant’. The fact...