[2014] UKFTT 1082 (TC)

Judge Jonathan Cannan, Miss Susan Stott FCA

Decision released 5 December 2014

Income tax – PAYE and national insurance contributions – Payments of interim dividends – Effect of reclassification prior to liquidation of company – Whether wilful failure to operate PAYE and pay national insurance – Whether directors liable for tax and national insurance because they knew of wilful failure – Income Tax (Pay As You Earn) Regulations 2003 (SI 2003/2682), reg. 72 – Social Security (Contributions) Regulations 2001 (SI 2001/1004), reg. 86 – Appeal allowed.

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