Strange v Revenue and Customs (NATIONAL INSURANCE CONTRIBUTIONS - Failure by limited company to pay NI contributions; Personal Liability Notice served on director; whether failure to pay attributable to neglect on the part of director; Social Security Administration Act 1992 sections 121C&D) [2025] UKFTT 298 (TC) (27 March 2025)

Strange v Revenue and Customs (NATIONAL INSURANCE CONTRIBUTIONS - Failure by limited company to pay NI contributions; Personal Liability Notice served on director; whether failure to pay attributable to neglect on the part of director; Social Security Administration Act 1992 sections 121C&D) [2025] UKFTT 298 (TC) (27 March 2025)

The Appellant, as sole director and officer, was responsible for ensuring NIC was paid to HMRC. He failed to do so for 22 months, prioritizing other payments despite being aware of his obligations. This conduct amounted to neglect under an objective standard, justifying the PLN and personal liability.

Citation
[2025] UKFTT 298
Parties
Appellant: John Strange; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
27 March 2025
Procedural Posture
Tax Appeal (personal Liability Notice) / First Tier Tribunal Decision
Outcome
Appeal dismissed
Legal Topics
National Insurance Contributions, Personal Liability Notice, Director Neglect, Statutory Duties of Directors, Appeals Procedure
Tax Law Social Security Law Company Law National Insurance Contributions Personal Liability Notice Director Neglect Statutory Duties of Directors Appeals Procedure

Case Brief

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Parties

John Strange

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (personal Liability Notice) / First Tier Tribunal Decision

Legal Issues

  1. 1 Whether there was an underpayment of NIC by the Company
  2. 2 Whether the Company's failure to pay NIC was attributable to neglect on the part of the Appellant
  3. 3 Whether the Appellant was acting as an officer of the company at the time of the failure to pay the NIC due

Ratio Decidendi

The Appellant, as sole director and officer, was responsible for ensuring NIC was paid to HMRC. He failed to do so for 22 months, prioritizing other payments despite being aware of his obligations. This conduct amounted to neglect under an objective standard, justifying the PLN and personal liability.

Court Disposition

Appeal dismissed

Orders

  • PLN issued to the Appellant upheld in full
  • Appellant held personally liable for NIC debt of £103,420.89