In D-Media Communications v HMRC [2016] UKFTT 430 (17 June 2016) the FTT found that it had appellate jurisdiction over the issue of a security notice and that the amount demanded by HMRC had been too high.
HMRC had issued a notice of security to D-Media in relation to PAYE and national insurance contributions (NICs) totalling £147 135 for a period of 24 months and D-Media appealed against the notice.
The FTT observed that whilst the need for protection of the revenue was common to VAT security cases and PAYE cases there was a significant difference in the way the legislation has been drafted in each case. The VAT security provisions only conferred a supervisory jurisdiction on the tribunal whilst the PAYE Regulations reg 97V(5) gave it an appellate jurisdiction. The tribunal could therefore set aside or vary the notice.
The FTT also thought that HMRC’s decision to...
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