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Were HMRC Reasonable To Issue A Notice Of Requirement (NoR)?

By Andrew Needham, March 2019

This was an appeal by the taxpayer against a decision by HMRC to issue a NoR to provide a security. 
 
The Appellant is 100% owned by Mr Samady and its trading activity is noted as being buying and selling real estate. 

HMRC considered that the Appellant represented a risk to the Exchequer due to a number of factors: 

  1. The company had VAT debts of £103,070.78, which included default surcharges of £13,382.45, and a PAYE debt of £96,760.39. 
  2. There had been 10 default periods and the default surcharge rate had been at the 15% rate since 11/16. 
  3. A related company, 37 Victoria Road Ltd, and which was also owned by Mr Samady, had a VAT debt of £411,695.51. 
  4. Another related company, CNM Estates
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