TC09158 - [2024] UKFTT 00369 (TC)

On 16 March 2015, Officer Idowu wrote to the Appellant stating that they had been unable to obtain sufficient evidence to trace the provenance of the Goods and verify that duty had been paid. The letter explained that goods held outside a duty suspension arrangement where excise duty had not been paid, relieved, remitted or deferred were considered to be released for consumption, and that the person holding the goods was liable to pay the duty evaded. Officer Idowu therefore raised the Assessment. On 14 April 2015, Officer Idowu wrote to the Appellant stating that records showed that the Appellant owed £46,749.

On 16 April 2015, the Appellant’s representative, Altion Law (“Altion”) wrote to HMRC stating that the Appellant was a recycling company and did not hold goods of the nature which were the subject of the Assessment.

On 9 June 2015, following further exchanges of correspondence, Altion wrote to HMRC requesting a review of the decision. The review conclusion was reached on 9 July 2015, upholding the Assessment.

On 7 August 2015, the Appellant lodged an appeal against the Assessment with the First-tier Tribunal (‘FtT’).