Heading

Neutral Citation: [2025] UKFTT 01066 (TC)
Case Number: TC09625
FIRST-TIER TRIBUNAL
TAX CHAMBER
By remote video hearing
Appeal references: TC/2013/03769
TC/2014/01267
EXCISE – appeal on basis that Appellant not the holder of the goods – application for disclosure from HMRC about supply chains and related matters – application allowed
Heard on: 19 August 2025
Judgment date: 2 September 2025
Before
TRIBUNAL JUDGE ANNE REDSTON
Between
UNITED WHOLESALE GROCERS LIMITED
Appellant
and
THE COMMISSIONERS FOR
HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Tristan Thornton of TT Tax, instructed by the Appellant
For the Respondents: Graham Mciver of Counsel, instructed by the Solicitor to the Office of the Advocate General
DECISION
- Heading
- Introduction
- The law
- Liability to excise duty
- The burden of proof
- Judicial review
- Disclosure
- The Application
- Mr Thornton’s submissions on behalf of UWG
- Mr Mciver’s submissions on behalf of HMRC
- Disclosure was inappropriate in principle?
- UWG failed to carry out appropriate checks?
- Judicial review
- Scope too wide/fishing expedition?
- Disproportionate?
- Particular supplies?
- Not fair and just?
- Flaws in the Application?
- Conclusions
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