First DJ mix from your favourite Part Time DJ turning Full Time!
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Vibes w/ Nics - Bashment & Soca Edition (DJ MIX)

out now on all dsps! 

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6PM in London w/ Nics

This podcast concerns a First-Tier Tribunal Tax Chamber decision regarding Seth Moffett Russell and Avenir EMS Ltd.'s appeal against a Notice of Requirement for unpaid PAYE and NICs. The appeal was significantly late, exceeding a six-month delay without sufficient justification. The Tribunal Judge, applying established case law, dismissed the application for late notification due to the serious nature of the delay, the lack of a valid reason for the lateness, and the exceptionally weak merits of the underlying appeal. The decision emphasizes the importance of adhering to statutory time limits. The judge considered all relevant circumstances and evidence, including the appellants' actions and the financial implications, before making her ruling.

Seth Moffett Russell & Anor v The Commissioners For HMRC [2024] UKFTT 1096 (TC)

This podcast discusses an Upper Tribunal decision documenting an appeal by Navin Joshi against a First-tier Tribunal ruling regarding the commencement date of his UK State pension entitlement. The core issue revolved around the late payment of voluntary National Insurance Contributions made by Mr. Joshi to meet the minimum qualifying years. Mr. Joshi argued his entitlement should begin when he reached pensionable age, but HMRC determined it started later, a decision partially adjusted to an earlier date through their discretionary powers. The tribunals ultimately upheld HMRC's revised commencement date, clarifying that late contributions are generally credited from the payment date, with limited discretion for earlier dates based on specific circumstances. The appeal was dismissed, reinforcing the statutory framework for State pension entitlement based on contribution history and payment timing.

Navin Joshi v HMRC [2025] UKUT 126 (TCC)

Write ft. Nics

This podcast discusses a First-Tier Tribunal (Tax Chamber) decision concerning an Inheritance Tax appeal by Ms. Annette Tonkin against HM Revenue and Customs. The core of the dispute revolves around a tax avoidance scheme her company entered into in 2012, aiming to pay Ms. Tonkin a bonus while avoiding income tax and National Insurance Contributions (NICs), and potentially inheritance tax. While Ms. Tonkin conceded the scheme was ineffective for income tax and NICs, the Tribunal focused on whether an additional inheritance tax charge applied under specific sections of the Inheritance Tax Act 1984, ultimately ruling in Ms. Tonkin's favor. The judgment explores the interpretation of "profits or gains" in tax law and whether the transfer of value was attributable to Ms. Tonkin for income tax purposes, leading to the appeal being allowed.

Annette Tonkin v HMRC [2025] UKFTT 750 (TC)

This podcast discusses the First-Tier Tribunal Tax Chamber in the appeals brought by GW Martin & Co Limited and Quadrant Surveying Limited against determinations issued by HMRC regarding a tax avoidance scheme. The central legal question addressed is whether certain payments made by the companies to their employees and directors constituted "earnings" subject to PAYE income tax and National Insurance Contributions (NICs) under sections of the ITEPA and SSCBA legislation. The Tribunal ultimately dismissed the appeals, finding that the payments were indeed earnings intended as a reward for services and that the corresponding obligation to subscribe for worthless, partially paid shares was merely a commercially irrelevant contingency designed to avoid taxation. As a result, the Tribunal upheld HMRC's original determinations for unpaid taxes and NICs.

GW Martin & Co Limited & Anor v HMRC [2025] UKFTT 1147 (TC)

This podcast discusses the UK Supreme Court judgment in the case of  HMRC v Forde and McHugh Limited, which addressed a tax appeal regarding liability for National Insurance Contributions (NICs). The core legal issue was the interpretation of the word "earnings" in the Social Security Contributions and Benefits Act 1992, specifically in the context of an employer’s contribution to a retirement scheme for an employee. The court considered whether an employer's transfer of funds into a trust, where the employee's interest was merely contingent upon reaching retirement age, counted as immediate earnings for NIC purposes. Writing the judgment, Lord Hodge rejected the tax authority’s argument, noting that while NIC "earnings" is generally broader than income tax "emoluments," taxing the initial contribution would be counter-intuitive and lead to potential double counting. The court ultimately concluded that the transfer into the contingent trust fund did not constitute the payment of "earnings" as defined by the 1992 Act, allowing the company's appeal.

HMRC v Forde and McHugh Limited [2014] UKSC 14

Full Time Rapper / Part Time DJ
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