Roseline Logistics v HMRC
A customs agent filed 32 declarations using postponed VAT accounting for a client who was not entitled to it. The tribunal upheld HMRC's demand against the agent for over £1.1m in import VAT.
An agent can face liability for invalid postponed VAT claims.
First-tier Tribunal · [2025] UKFTT 427 (TC) · 15 April 2025
What happened
Roseline Logistics submitted 32 import declarations between January and May 2022, ostensibly on behalf of QP Trading Limited. Each declaration used postponed VAT accounting (PVA), a mechanism that lets eligible importers account for import VAT on their VAT return instead of paying it at the border.
Why HMRC challenged it
HMRC found that the named importer was not entitled to use PVA at the relevant time. On 13 March 2023 it issued a post-clearance demand for £1,126,249.64 in import VAT. The dispute concerned whether Roseline, as the customs agent/declarant, was jointly and severally liable for that unpaid VAT.
What the tribunal decided
The tribunal dismissed Roseline's appeal. Applying the statutory liability provisions, it held the company liable and rejected its argument that imposing liability breached its rights under the European Convention on Human Rights. The demand against Roseline stood.
What this means for businesses
Eligibility for postponed VAT accounting must be checked before declarations are submitted. This was an import VAT and agent-liability case, not a tariff-classification case; it does not establish that every broker error leaves only the importer liable.
Case summary, not the complete judgment. Read the original decision for the full facts and reasoning.