TC09670 - [2025] UKFTT 01260 (TC)
First-tier Tribunal (Tax Chamber)

TC09670 - [2025] UKFTT 01260 (TC)

Fecha: 23-Oct-2025

Introduction

Introduction

1.

With the consent of the parties, the form of the hearing video over Teams. The documents to which we were referred were a hearing bundle of 355 pages. and a skeleton argument from each party.

2.

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings. As such, the hearing was held in public.

3.

This is an application to make a late appeal. As well as the documentary evidence we heard oral evidence from Mr. Jack Atkins of The VAT People T/A The Customs People, who represent the Appellant. Mr. Vallis cross-examined Mr. Atkins. We found Mr. Atkins to be an honest and credible witness.

4.

The underlying decision that the Appellant seeks permission to appeal against late is a C18 demand for customs duty of £878,730.54 and Import VAT of £174,234.56, a total sum of £1,052,965.00. The C18 was issued on 31.10.24 on the basis that the Appellant’s imports of goods from Morocco did not qualify for preferential customs treatment based on their origin.

5.

On 13.12.24 The Customs People requested an independent review of the decision to issue the C18 on the basis that the Rules of Origin governing preferential origin between the UK and Morocco were met for at least some of the consignments in question.

6.

On 17.1.25 HMRC notified the Appellant of the review conclusion, upholding the C18.