PAYE54155 - Employer returns: regulation 80 determinations: onus of proof
For normal time limit determinations it is the employer's duty, on appeal, to show that the determination is wrong. For extended time limit determinations the onus is on the Higher Officer to show that tax was deliberately understated and or concealed.
The Tribunal caseworker within the Appeals Unit should be ready to explain to the Tribunal why you had to determine the tax. You may have to use the Employer Help Book E13 and Taxable Pay Tables to show from the Regulations how PAYE works.

