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Mr O�Grady, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents
This is an appeal by the Appellant against the penalty imposed by HMRC under Schedule 56 Finance Act 2009 for the late payments of PAYE during the tax year 2010/2011.
The legislation was not in dispute but it may be helpful at this point to set out the relevant provisions.
Regulation 69 Income Tax (PAYE) Regulations 2003 (SI 2003 No 2682) determines when an employer must pay amounts of tax required to be deducted under Regulation 68 (2).
(1) A penalty is payable by a person (�P�) where P fails to pay an amount of tax specified in column 3 of the Table below on or before the date specified in column 4.
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