A company’s claim that payments made to directors were erroneously treated as remuneration, and were actually dividends, was rejected due to a lack of sufficient evidence.
Summary
The appellant company’s claim that payments made to director shareholders were erroneously treated as remuneration, and were actually dividends, was rejected due to a lack of sufficient evidence, and its appeal against PAYE income tax and National Insurance contributions (NIC) liabilities was therefore dismissed.
Background
The appellant company originally submitted PAYE forms P35 and P14 for the tax years 2007/08 to 2010/11 inclusive on the basis that certain payments made to its directors were remuneration. Accounts submitted annually to HM Revenue & Customs (HMRC) for accounting periods ended 30 June 2011 supported the P35 figures.
The company
