HM Revenue and Customs (appellant) v Malde and another (respondents)
Tuesday 28 – Thursday 30 October 2025
By Appellant’s Notice filed on 28 January 2025 the Appellant (Appellants below) HMRC, appeal the decision of Mr Justice Edwin Johnson and Judge Ashley Greenbank, sitting as a Judges of the Upper Tribunal, judgment being delivered on 7 November 2024.
It is HMRC’s case that SA and Global were involved in the fraudulent diversion of alcohol into the UK from the EU by a process known as “inward diversion fraud” resulting in unpaid VAT and excise duties.
As a result of an investigation, HMRC concluded that SA and Global were controlled by Mr Malde, and that SA and Global had evaded VAT and excise duties on alcohol supplied in the UK by falsely declaring that the goods were destined for other EU countries or were in duty suspension.
Mr Malde appealed to the First Tier Tribunal (FTT) against each of the personal liability notices (“PLNs”) and the director’s liability notices (“DLNs”) that were issued to him, and also against the assessments made against Global by HMRC. The FTT upheld the appeals. HMRC appealed the decision to the Upper Tribunal (“UT”)
HMRC now appeal the UT’s decision.
View hearing:
Day 1:
Day 2:
Day 3: