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Roseline Logistics Ltd v HMRC

Agent liability to pay VAT on imports

In Roseline Logistics Ltd v HMRC [2025] UKFTT 427 (TC) (15 April) the FTT dismissed an appeal against a post-clearance demand note in respect of the improper use of postponed import VAT accounting by a logistics firm.

In this case HMRC issued the appellant (Roseline) with a post-clearance demand note in respect of import VAT. This related to 32 import declarations Roseline made in a specified period ostensibly on behalf of a company QP Trading Ltd (QPTL). Roseline made the declarations whilst acting (or purporting to act) as a customs agent for QPTL. Each of the declarations utilised post import VAT accounting (PIVA) the effect of which is to enable the trader to account for import VAT in its VAT return rather than paying VAT at the point of import and this method of VAT accounting is...

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