Spring Salmon & Seafood v HMRC

In Spring Salmon & Seafood v HMRC [2014] UKFTT 887 (11 September 2014) the FTT found that determinations issued by HMRC were valid.

Spring Salmon & Seafood carried on business as suppliers distributors and processors of seafood. Mr Thomas was its director. He also carried on a business in partnership with his brother as consultants and seafood dealers.

The main issue was the liability if any of the company to pay PAYE and NIC in respect of a £900 000 bonus to Mr Thomas and his brother and wages and salaries of £178 230. The FTT had to decide whether the monies had been paid by the company to the individuals whether HMRC’s determinations were time-barred and whether an alleged 2007 agreement barred HMRC from pursuing the liabilities.

The FTT observed that the company’s cessation accounts referred to the £900 000 bonus which was...