Precision Fabrications Andover Ltd & Ors v The Commissioners for HMRC

Decision date: 28 August 2026

Neutral citation: [2026] UKFTT 1255 (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 (NORs) for security for PAYE and NICs issued 13 June 2025. The Tribunal held HMRC's decision that security was necessary was one reasonably open to it on the date of the NORs and confirmed the NORs, but exercised its power to extend the compliance date, setting a 60‑day period for provision of security. The appeal was therefore dismissed in substance while the compliance date was varied.

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 treated its jurisdiction as mixed: the core question whether security was necessary under Reg 97N is subject to supervisory review limited to the facts known to HMRC when the NOR was issued, whereas Reg 97V(5) gives the Tribunal appellate power to vary the specific requirements in the notice (amount, timing, duration, manner), allowing it to substitute its own view on those specified requirements. The Tribunal also concluded that Reg 97V(7)(a) permits it to set an alternative compliance date when making a final determination.

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 noted that authorities concerning VAT security are of limited relevance because the PAYE/NICs regime expressly permits variation of notice requirements, and observed that HMRC could not reconcile a purely supervisory jurisdiction with the statutory power to vary requirements under Reg 97V(5).

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