Summary
HM Revenue and Customs (HMRC) did not need to take into account the financial consequences of cancelling a company’s construction industry scheme (CIS) gross payment registration (under FA 2004, s 66).
Background
The respondent company’s registration for gross payments under the CIS was, as with other registered taxpayers, subject to ongoing review by HMRC to ensure compliance with the conditions for gross payment registration.
HMRC conducted an annual compliance review on 30 May 2011, which the respondent failed due to late payment of PAYE. The respondent changed its systems significantly after July 2011 to ensure that PAYE was paid on time. However, HMRC noted that this was the respondent's third failed review, and cancelled its registration for gross payment (under FA 2004, s 66(1)). The respondent appealed against the cancellation (under s),
