An appeal against a PAYE determination for 2010/11 was allowed due to insufficient evidence of an amended notice of coding having been issued, but a similar appeal against a determination for 2011/12 was dismissed on the evidence.
The appellant company employed an individual (PF) for a period including the tax years 2010/11 and 2011/12. The records of HM Revenue and Customs (HMRC) for the appellant indicated that PF’s tax code for 2010/11 changed on 8 November 2010. However, there was no copy or record of the coding notice having been generated and issued to the employer.
HMRC’s records also indicated a change in PF’s tax code for 2011/12. HMRC’s copy of the tax code notice issued to the appellant in respect of PF showed an issue date of 10 March 2011.
In July 2014, HMRC issued two determinations (under the Income Tax (Pay As You Earn) Regulations 2003, SI 2003/2682, reg. 80) for
