In UBI Ltd v HMRC [2018] TC06771, the FTT agreed that a company with a poor compliance record was reasonably required to provide HMRC with security for PAYE liabilities. It failed to keep to a time to pay agreement. 

HMRC required the company to provide more than £110,000 in security for PAYE liabilities.

The company failed to attend the tribunal hearing, and three times refused to speak to the tribunal when a clerk telephoned.

On reviewing the papers, the tribunal dismissed the first two arguments as clearly untrue. The third argument was unsupported by any accounts or other evidence.


It is quite unusual for HMRC to require security from an existing business.

Useful guides

PAYE Real Time Information Reporting (RTI)
Essentials for employers

RTI late filng penalties
Penalties for failure to submit returns

PAYE late payment penalty buster
What to do if you can't pay, and how to avoid extra late payment penalties


Case report UBI Ltd v HMRC [2018] TC06771