The First-tier Tribunal (FTT) did not have jurisdiction to consider whether the conditions were satisfied for relief to be granted from liability for unpaid CIS deductions for periods prior to registration under the scheme, and in any event, the FTT would not have made such a direction as the appellants were not considered to have taken reasonable care.
The appellant companies (‘NP’ and ‘CT’) were special purpose vehicles set up to purchase and redevelop sites in Liverpool. NP and CT were connected. Both developments involved carrying out construction operations within the ambit of the construction industry scheme (CIS). The appellants engaged sub-contractors to carry out their respective commercial developments and signed contractual agreements with those sub-contractors. The contracts were dated 5 August 2015, 1 March 2016 &
