The appeal by NWM Solutions Limited was made for a tax demand for £509,840.62 issued by HMRC under Regulation 80 of the Income Tax Regulations 2003.

HMRC said that NWM did not meet all the conditions imposed according to a PAYE dispensation covering subsistence expenses.

As a result, HMRC said that the company owed tax for the tax years ended 5 April 2014, 2015, and 2016, totalling £509,840.62.

NWM and HMRC had entered into ‘without prejudice’ discussions regarding the quantum of the tax and National Insurance contributions (NICs) at issue in the appeal.

On 1 November 2017, HMRC issued the determinations and argued that there was ‘ample evidence’ to show that the determinations undercharged NWM to tax as a result of the quantum issue raised in a letter, which was issued on 25 June 2019.

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