IPSC Recriutment Ltd v Revenue and Customs (VAT - PAYE/NICs) [2026] UKFTT 247 (TC) (20 January 2026)

IPSC Recriutment Ltd v Revenue and Customs (VAT - PAYE/NICs) [2026] UKFTT 247 (TC) (20 January 2026)

HMRC's decision to issue the Notices of Requirement for security was reasonable based on the Appellant's own compliance failures, outstanding tax liabilities, and relevant connections to previous failed companies with substantial tax debts. The Appellant's inability to pay or business hardship was irrelevant to the...

Source-derived case information.

Citation
[2026] UKFTT 247 (TC)
Parties
Appellant: IPSC Recruitment Ltd; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
20 January 2026
Procedural Posture
Tax Appeal (vat and Paye/nics Security Notices) / First Tier Tribunal (tax Chamber) Full Judgment After Remote Hearing
Outcome
Appeal dismissed
Legal Topics
VAT Security Notice, Paye/nics Security Notice, Reasonableness of HMRC Decision, Joint and Several Liability, Phoenix Companies
Tax Law VAT Security Notice Paye/nics Security Notice Reasonableness of HMRC Decision Joint and Several Liability Phoenix Companies

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Parties

IPSC Recruitment Ltd

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (vat and Paye/nics Security Notices) / First Tier Tribunal (tax Chamber) Full Judgment After Remote Hearing

Legal Issues

  1. 1 Whether HMRC's decision to issue Notices of Requirement for security was reasonable
  2. 2 Whether connections to previous failed companies justified the NoRs
  3. 3 Whether inability to pay or business hardship is relevant to the reasonableness of NoRs

Ratio Decidendi

HMRC's decision to issue the Notices of Requirement for security was reasonable based on the Appellant's own compliance failures, outstanding tax liabilities, and relevant connections to previous failed companies with substantial tax debts. The Appellant's inability to pay or business hardship was irrelevant to the reasonableness of the NoRs. Even absent the connections to previous companies, the Appellant's own conduct justified the NoRs.

Court Disposition

Appeal dismissed

Orders

  • Both Notices of Requirement for security (VAT and PAYE/NICs) are upheld.