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First-tier Tribunal held HMRC reasonably required PAYE and NIC security, but fixed a 60-day compliance period for the appellants.
The FTT did not err in law in refusing permission to appeal out of time; it correctly applied the Martland principles, considered all relevant circumstances including the seriousness of delay, lack of good reason, and the importance of time limits, and gave due weight to the potential criminal consequences. The likelihood of success in the substantive appeal does not override the need to respect statutory time limits. There was no breach of Article 6 ECHR or unfairness in the procedure adopted.
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