Crescendo Entertainment Ltd (now in liquidation) & Anor v The Commissioners for HMRC

Decision date: 28 October 2026

Neutral citation: [2026] UKFTT 1495 (TC)

Overall AI summary confidence: high

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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

This appeal challenged HMRC notices of requirement to give security (NORs) issued 12 March 2025 to Crescendo Entertainment Ltd and its sole director for PAYE and NICs totalling £186,984.78. The tribunal held the decision-maker knew the appellants were impecunious, failed to consider their ability to pay or hardship, and so the NORs were unreasonable and disproportionate. After the company was wound up and HMRC declined to pursue the director, the tribunal allowed the appeals and set the NORs aside.

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

When issuing a NOR under the PAYE/NIC provisions an officer must assess proportionality by taking account of the recipient’s hardship and ability to pay; a NOR is disproportionate where the decision-maker knows the recipient cannot, in practice, provide the security such that the notice cannot achieve real protection of the revenue.

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 judgment observes that, although the NOR regime may be proportionate in general, it can operate disproportionately in particular cases; and that consequences which are inevitable and inextricably linked to issuing a decision (for example winding-up or inevitable criminal liability) may be relevant to assessing the lawfulness and purpose of the decision.