Not prejudicial

HMRC had issued regulation 80 determinations in respect of PAYE liabilities on the appellant company. At the same time they issued notices of decision under Social Security Contributions (Transfer of Functions etc.) Act 1999 s 8 in respect of National Insurance liability to P Ltd rather than to the appellant.

The taxpayer appealed against the reg 80 determinations. HMRC subsequently issued revised s 8 notices on the appellant. The appellant appealed against this also.

HMRC applied to have the appeal against the revised decision heard at the same time as the PAYE appeal.

The issues arose as to whether there was sufficient notice to bring the later appeal before the Special Commissioner and also whether the PAYE and National Insurance appeals should be heard together.

The Special Commissioner decided that it would be beneficial to hear the PAYE and National Insurance appeals together. If any...