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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 appellant’s shortage of funds was not attributable to events outside his control; he failed to make provision or arrange borrowings for tax liability, prioritised other commitments, and relied on uncertain forecasts and TTP offers. The exception for reasonable excuse did not apply. Penalties were correctly charged under Schedule 56 FA 2009.
Source excerpt
Section 108 FA 2009 did not apply because Pracyva’s request for deferral was made after the due date for payment for period 9/21. Pracyva’s cashflow difficulties, health and family issues, and late approach to HMRC did not amount to a reasonable excuse for late payment under section 59(7) VATA.
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