FieldworkHub Ltd v The Commissioners for HMRC
Decision date: 11 September 2025
Neutral citation: [2025] UKFTT 1097 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
FieldworkHub Ltd appealed an HMRC Regulation 80 Determination that it had failed to deduct PAYE from an employee (Ms S) for 2021/22 because previous employment pay/tax figures were not included in its payroll calculations. The Tribunal found the PAYE Regulations did not oblige the employer to include other-employment figures in its deductions working sheets absent a P45 or HMRC-supplied first-code figures, allowed the appeal and reduced the Determination to nil.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
The Tribunal identified that, where no P45 is provided, an employer's duty to include previous employment pay and tax details in its deductions working sheets arises only if HMRC supplies those figures with the first tax code for the year; without such provision, there is no regulatory obligation to include them. It also held that a Regulation 80 Determination must be supported by evidence that the employer failed to comply with the Regulations, and absent such evidence the Determination can be reduced to nil.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal observed that, had there been an obligation, a very small employer that prudently relies on a professional payroll provider and has taken reasonable care might qualify for relief under the Regulations. It also suggested that HMRC asserting a later code was the "first" in the tax year without explaining the origin of figures may be insufficient to establish employer liability.