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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.
As at 1 December 2017, BSC’s UK Branch did not have sufficient human and technical resources under its comparable control to constitute a fixed establishment in the UK. The activities were preparatory or auxiliary, and there was no evidence of necessary control over resources. Therefore, BSC was not eligible to join the VAT group. Even if eligible, the VAT savings would have been within the normal consequences of grouping, so refusal for protection of the revenue would not have been reasonable. The appeal is dismissed.
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