Sentencing — applying tax deductions for other purpose than accounting to IRD — PAYE — Zaheed v R [2010] NZCA 573 — R v Easton [2013] NZCA 677 — Clancy v Inland Revenue Department [2017] NZHC 2029. The defendant appeared for sentence on nine charges of applying tax deductions for a purpose other than accounting to the Inland Revenue Department (IRD). He had made deductions for tax and other payments owing to the employees of his company, and held the amounts in trust. The defendant had received warnings from IRD that it was a criminal offence to fail to make PAYE payments, but eventually he was charged for failing to pay $491,447.31 over nine separate payment periods. The Court observed that the offending could have been more serious in that the defendant had simply failed to pay what he owed rather than attempting to hide the fact that he owed the debt in the first place. The start point for sentence was two years' imprisonment, and the Court allowed reductions for guilty plea, otherwise good character, cooperation with the investigation and efforts to pay reparations. The final sentence was six months' community detention, 300 hours' community work and reparation payments. Judgment Date: 16 September 2020.