Why the client needed our help
A business owner sought our assistance after receiving a Personal Liability Notice from HMRC demanding more than £500,000 in unpaid customs duty. The notice stemmed from an international trading structure involving imports and exports between China and the UK. HMRC alleged that goods had been imported without the correct declarations and attempted to hold the client personally liable for a significant duty shortfall.
The demand created substantial personal and commercial risk. Despite the client having followed established compliance procedures, HMRC continued to pursue the claim. The situation required specialist advice on HMRC enforcement, personal liability notices and the tribunal process in England and Wales.
How we helped
We carried out a detailed review of the client’s trading records, accounting documentation and import processes. We engaged with HMRC throughout the internal review stages and clarified the steps the client had taken to meet their obligations.
As it became clear that HMRC intended to maintain the Personal Liability Notice, we prepared the matter for appeal before the First-tier Tax Tribunal. This involved assembling a comprehensive bundle of more than 2,500 pages, including witness evidence, exhibits and written submissions. We worked closely with counsel to draft a clear and persuasive skeleton argument, presenting the client’s position in a structured and compelling way.
The Outcome
The client achieved a complete success. Shortly after receiving our submissions, HM Revenue & Customs withdrew the claim in full. The £500,000 demand was removed within days, bringing an end to a lengthy and stressful dispute.
The client was able to continue trading without the burden of personal liability and move forward with confidence.
