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 Notices of Requirement for security for VAT and PAYE/NICs was reasonable based on the Appellant's own failure to pay tax liabilities, its connections to previous defaulting companies, and the involvement of individuals previously associated with substantial tax losses. Inability to pay or...

Source-derived case information.

Citation
[2026] UKFTT 247
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) Judgment on Appeal Against Notices of Requirement for Security
Outcome
Appeal dismissed
Legal Topics
VAT Security Notice, Paye/nics Security Notice, Reasonableness of HMRC Decision, Supervisory Jurisdiction, Joint and Several Liability, Phoenix Companies
Tax Law Administrative Law VAT Security Notice Paye/nics Security Notice Reasonableness of HMRC Decision Supervisory Jurisdiction 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) Judgment on Appeal Against Notices of Requirement for Security

Legal Issues

  1. 1 Whether HMRC's decision to issue Notices of Requirement for security for VAT and PAYE/NICs was reasonable
  2. 2 Whether the Appellant's business was sufficiently connected to previous defaulting companies to justify the NoRs
  3. 3 Whether inability to pay or business hardship is relevant to the reasonableness of the NoRs

Ratio Decidendi

HMRC's decision to issue Notices of Requirement for security for VAT and PAYE/NICs was reasonable based on the Appellant's own failure to pay tax liabilities, its connections to previous defaulting companies, and the involvement of individuals previously associated with substantial tax losses. Inability to pay or business hardship is not a relevant consideration. Even absent the connection 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.