The accelerated payment notice regime was not prevented from applying to liabilities for PAYE income tax which were the subject of a determination made by HMRC under regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003, SI 2003/2682.
In February 2016, HM Revenue and Customs (HMRC) made a regulation 80 PAYE determination against the appellant company and corresponding decisions for National Insurance contributions (NICs) purposes, in respect of payments made to two directors.
