Tax Law · First-tier Tribunal (Tax)
Precision Fabrications Andover Ltd & Ors v The Commissioners for HMRC
Checked against the judgment on 10 September 2026 · how we verify
Facts
Precision Fabrications Andover Ltd and its two directors, Mr Jonathan Lees and Ms Caroline Lees, appealed against Notices of Requirement to give security issued by HMRC on 13 June 2025 under Part 4A of the Income Tax (Pay As You Earn) Regulations 2003 and Part 3B of Schedule 4 to the Social Security (Contributions) Regulations 2001. The notices required the appellants, jointly and severally, to provide security of £150,109.12 — £68,351.04 for PAYE and £81,758.08 for NICs — by 23 July 2025, to be held for 24 months. HMRC's case was that security was necessary for the protection of the revenue given the company's repeated failures to pay PAYE and NIC liabilities in full and on time, despite warning letters issued in September 2023, November 2023 and September 2024, successive Time to Pay arrangements, and the withdrawal in February 2025 of an earlier Notice of Requirement authorised the previous month. The appellants said the arrears sprang from exceptional cashflow pressures: the insolvency of a significant customer costing roughly £160,000, slower-paying replacement customers with lower credit limits, bad debts, consequent strain on the company's invoice factoring arrangements, and an awaited Research and Development tax relief repayment. They appealed on 25 June 2025; HMRC upheld the notices on review on 19 September 2025, and the appeal was notified to the Tribunal on 15 October 2025.
What did the court decide?
Four things on this page are for subscribers:
- The decision: what the court actually held
- The issues: the questions it had to answer
- The reasoning: how it got there, in its own logic
- The case history: every step, court by court
CaseLawDigest reads every judgment published on Find Case Law for England and Wales, files it by practice area, and writes a summary a practitioner can use. One weekly PDF per area, and the full archive here.
One practice area is £19 a month, and the weekly PDF lands in your inbox.
See the plans Or take the free digestOn your firm’s subscription? Set up your access. Already have an account? Sign in.