TC09158 - [2024] UKFTT 00369 (TC)

The Assessment relates to Goods collected from the Appellant’s premises on 3 August 2012 and 15 August 2012. Following the first visit on 5 December 2012 by the FIS, an investigation ensued and an illicit supply chain was revealed, where various third-party hauliers were interviewed. Further work was, however, required to be done before the Assessment was raised.

In relation to whether the Assessment was made in time, the clock started ticking when the Visit took place in 2014, and the results of HMRC’s investigation were given to Mr Boyle.

HMRC are satisfied that three separate arm’s length entities have identified the Appellant’s premises as being where the duty point arose as the Goods were collected from the Appellant’s premises.

There are separate legislative provisions in relation to the Assessment and the Penalty. The Appellant’s position is misconceived in relation to liability to either, or both.