This was an appeal by the taxpayer against an assessment by HMRC for underdeclared output tax.

The appellant appealed against assessments totalling more than £6.5m in relation to 1,311 separate deposits at 42 different UK branches of Barclays Bank into an account held by Award Drinks totalling £32,650,305.89. The assessments were reduced on 23 December 2015, ‘leaving only those transactions where HMRC consider that the origin of the payments has not been sufficiently evidenced’.

The ground of appeal advanced was that these sums deposited into UK bank accounts by couriers were payments for in-bond sales of alcohol from bonded warehouses in France to cash and carry operators in France. The money was paid in pounds sterling, as that was the currency accepted by these outlets from UK ‘booze cruise’ tourists. The appellant contended that as there were no taxable supplies in the UK, its appeal against the assessments should.<