Delphi Derivatives Limited appealed against two penalty assessments issued by HMRC totalling £1,572,260.16 about the company’s PAYE returns on form P35 for the employee benefit trust (EBT).

HMRC said the P35 returns contained a ‘careless’ inaccuracy in a 2008-09 return, and a ‘deliberate’ inaccuracy in a 2009-10 return.

These errors were related to Delphi’s participation in a tax planning scheme used to pay directors.

Mark Langran incorporated Delphin on 12 July 2001, with its principal trade to broke and trade futures and options on the London Metal Exchange.