Strikeout

A taxpayer company appealed against PAYE and National Insurance (NI) determinations raised in respect of shares transferred to employees out of an employee benefit trust.

HMRC applied for the appeals to be struck out on the ground the decision in CRC v PA Holdings Ltd [2012] STC 582 applied.

The instant taxpayer did not attend the First-tier Tribunal (FTT) hearing and the judge struck out the appeal. He said:

“It is not open to an appellant simply to take no part in the proceedings and to expect the tribunal to undertake its own analysis. That in effect is expecting the tribunal to stand in the shoes of the appellant and to make out a case for the appellant before making a determination as between that case and the case put forward by the respondents.”

The company applied for its appeal to be reinstated –...