HMRC was not estopped from retrospectively collecting NICs from the appellants, notwithstanding an earlier agreement between the parties that certain cars leased by the appellants and used by employees would be ‘pool cars’ for NICs purposes if certain conditions were satisfied.
Summary
HM Revenue and Customs (HMRC) was not estopped from retrospectively collecting National Insurance contributions (NICs) from the appellants, notwithstanding an earlier agreement between the parties that certain cars leased by the appellants and used by employees would be ‘pool cars’ for NICs purposes if certain conditions were satisfied.
Background
In 1993, HMRC carried out a PAYE audit of the appellants. At a meeting between the parties, an agreement was subsequently 
