In Hearne V O’Cionna 1988 IV ITR 113 it was held that a person who paid emoluments on behalf of another was liable to account for PAYE thereon.
Even where a ‘one off’ payment is made, PAYE must be operated. Booth v Mirror Group of Newspapers plc 1992 STC 615
It was held in Kirkshell Timber Ltd v Revenue & Customs Commissioners 2006 SpC 559 that the assignment of book debts to a director constitutes payment subject to PAYE.
Revenue assessed the company director to income tax deducted by an employer and not remitted to the collector general. 13TACD2019