Thyssenkrupp Materials (UK) Ltd v HMRC

In Thyssenkrupp Materials (UK) Ltd v HMRC [2022] UKFTT 443 (TC) (30 November 2022) the FTT decided that a failure to provide accurate and complete information to HMRC in relation to a quantity of goods on which inward processing relief (IPR) had been claimed gives rise to a customs debt not just in relation to that quantity of goods but on all the goods covered by the relevant bill of discharge report. The decision was made on the basis that it was consistent with the CJEU judgment in Döhler Neuenkirchen GmbH v Hauptzollamt Oldenburg (Case C-262/10) (‘Döhler’).   

The appeal by Thyssenkrupp was against a decision by HMRC to issue a C18 post clearance demand note in the amount of £8 889 275.43. The HMRC letter accompanying the C18 included the following words: ‘failure to comply with an obligation arising...