LEXLAW Solicitors & Barristers
A HMRC Time to Pay (TTP) arrangement lets businesses spread unpaid tax over manageable monthly instalments. In 2026, with HMRC enforcement increasing, well-prepared TTP proposals backed by financial evidence help avoid winding-up petitions, protect directors, and keep businesses trading.
In Purkiss v Kennedy, the High Court rejected a liquidator’s attempt to recover unpaid PAYE and NICs from Ethos Solutions Ltd’s failed tax avoidance scheme. The court found no fraudulent intent to evade HMRC under Insolvency Act 1986, Section 423. This case highlights HMRC’s challenges in tax recovery via insolvency law and the need to prove intent.
HMRC have been using Horizon Data to raise tax assessments and tax penalties against innocent sub-postmasters. In one such case only after a six year battle when HMRC faced paying costs did they decide to withdraw their tax demands. Even now they refuse to recognise their misconduct should be punished by them paying indemnity costs and have threatened the sub-postmaster victim with a costs order simply for daring to ask for his full costs.
A HMRC Security Notice is a formal notice issued by HM Revenue and Customs (HMRC) to an individual or business requiring them to provide security for certain future tax liabilities. It is a tool used by HMRC where they believe there is a risk of tax loss.
Our Director Liability litigation team review this recent judgment where a liquidator lost a claim for breach of director’s duties over a tax avoidance scheme.
This article provides an overview of Inheritance Tax (IHT) in the UK, explaining its objectives, historical development, and current operation under the Inheritance Tax Act 1984. It critically examines the fairness and efficiency of the tax and explores proposals for reform. The content is designed to help clients understand how IHT affects estate planning and wealth transfer. For professional advice tailored to your circumstances, contact Lexlaw Solicitors.