Summary 

This was an appeal against a Personal Liability Notice issued to the appellant under paragraph 19 of Schedule 24 to the Finance Act 2007 in the amount of £31,933.30 for the VAT accounting periods 11/15 to 08/17, on the grounds that he had continued to submit VAT returns using Cash Accounting HMRC had withdrawn permission to use that basis.  

Background 

The appellant was a director of PMR Limited (‘PMR’), Castle Developments (Wales) Limited (‘CDW’) and Court Estates & Developments Limited (‘CED’). Initially there were other directors of CDW but by the time of the events under consideration the appellant was the sole director of all three companies. 

In July 2007, PMR was engaged to carry out the project management of a development site which consisted of 26 residential properties, whilst CDW was