The decisions of HM Revenue and Customs (HMRC) requiring the appellant company to give security for VAT, PAYE and National Insurance contributions (NICs) were logical and coherent and proportionate to the risk to the revenue posed by the appellant company. 

Background

The appellant company was incorporated on 2 June 2017 under the name BCW Sales Ltd. The appellant’s directors were also directors of another company, Bluechipworld Sales & Marketing Ltd, which went into administration on 31 August 2017. On 4 September 2017, Bluechipworld Sales & Marketing Ltd changed its name and the appellant took over that name. The appellant operated the same trade (electronic and telecommunication parts) as the company that went into administration. The previous company had debts to HMRC in excess of £91,000 in relation to PAYE and NICs and £69,000