Rikki Cann Ltd v Revenue and Customs (CUSTOMS DUTY : Reliefs) [2016] UKFTT 538 (TC) (02 August 2016)

Rikki Cann Ltd v Revenue and Customs (CUSTOMS DUTY : Reliefs) [2016] UKFTT 538 (TC) (02 August 2016)

CARS was not empowered to act on behalf of Rikki Cann Limited for SIP procedure obligations; even if it had been, appellant's failures did not imply obvious negligence and extensions would have been granted, so customs debt was not incurred under Article 859.

Citation
[2016] UKFTT 538
Parties
Appellant: Rikki Cann Limited; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
02 August 2016
Procedural Posture
Tax Appeal / First Tier Tribunal Decision
Outcome
Appeal allowed
Legal Topics
Inward Processing Relief, Agency Authority, Customs Debt, Negligence Under Article 859

Case Brief

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Parties

Rikki Cann Limited

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal Decision

  1. 1 Whether shipping agent had authority to designate appellant as responsible under SIP procedure
  2. 2 Whether appellant was obviously negligent for purposes of Article 859 of Regulation (EEC) No 2454/93
  3. 3 Whether exceptions under Article 859 apply to relieve customs debt

Ratio Decidendi

CARS was not empowered to act on behalf of Rikki Cann Limited for SIP procedure obligations; even if it had been, appellant's failures did not imply obvious negligence and extensions would have been granted, so customs debt was not incurred under Article 859.

Court Disposition

Appeal allowed

Orders

  • Post Clearance Demand Note set aside
  • No customs duty, VAT, or interest payable by appellant