I was employed by a company in 05/06 and 06/07, who used to pay partially in loans from an offshore EBT.
HMRC are now saying that the PAYE tax needs to be paid on these loan payments.
HMRC had already opened an enquiry into my SA for 06/07, so depending on the outcome of the case, I may have to pay the PAYE for that year.
My question is regarding the other year (05/06), for which there was never an enquiry open, and is obviously more than 6 years ago. Can HMRC use the 20 year 'deliberate behaviour' rule, if everything I did was at the direction of my employer?
Many Thanks
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