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 the company's failure to pay NIC, which was attributable to his neglect. He prioritized payments to himself and others over statutory obligations to HMRC, despite being fully aware of those obligations. Financial difficulties and threats did not excuse non-compliance. The PLN was properly issued and the appeal is dismissed.

Citation
[2025] UKFTT 298 (TC)
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, Final Judgment
Outcome
Appeal dismissed
Legal Topics
National Insurance Contributions, Personal Liability Notice, Director's Neglect, Statutory Duties of Directors, Appeal Procedure
Tax Law Social Security Law Company Law National Insurance Contributions Personal Liability Notice Director's Neglect Statutory Duties of Directors Appeal 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, Final Judgment

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 the company's failure to pay NIC, which was attributable to his neglect. He prioritized payments to himself and others over statutory obligations to HMRC, despite being fully aware of those obligations. Financial difficulties and threats did not excuse non-compliance. The PLN was properly issued and the appeal is dismissed.

Court Disposition

Appeal dismissed

Orders

  • PLN issued to the Appellant in the sum of £103,420.89 is upheld in full