The sticking point is that the Inspector wants a Certificate of Full Disclosure of all of the Director's personal assets in conjunction with his personal Statement of Assets and Liabilities. I find this totally unacceptable. When the Inspector asked me why I said "because he isn't the taxpayer". He is wearing his third party hat by paying on behalf of the company.
Would i be correct in saying that your client the individual has a debt to the company that could be chased in full presumably if hmrc were owed matching assessments of tax and associated penalties and that you are wanting to quibble over the technicalities with regard to the timing of the s455 tax and other taxes that need to be paid.
If that is the case are you not the one playing hardball not offering a reasonable route to get this closed without things potentially turning more serious?
I fully understand the logic of the route you are taking as hmrc never seem to chase the obvious route here if the individual has a debt to the company and the company has a debt to hmrc.
Perhaps i am missing something when i feel that if it is his debt he should be willing to provide information to prove that he doesn't particularly have the means to pay this debt. As you say though rules is rules and he isn't the company and perhaps i am missing something subtle here.