Conqueror Trading Limited & Ors v The Commissioners for HMRC
Decision date: 11 November 2025
Neutral citation: [2025] UKFTT 1335 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
Four UK trading companies appealed HMRC post‑clearance demands for customs duty and import VAT after HMRC queried undervaluation and denied onward supply relief (OSR). The Tribunal found HMRC had reasonable doubts about the declared transaction values, the appellants failed to discharge evidential burdens on valuation and OSR, and HMRC lawfully applied a Method 6 valuation fallback. The appeals were dismissed and HMRC’s assessments upheld.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
Where HMRC have reasonable doubts about declared transaction values under the relevant Union Customs Code provisions and enquiries do not dispel those doubts, they may lawfully determine customs value using secondary methods (including a data‑driven Method 6 fallback); importers bear the evidential burden to prove declared values and entitlement to OSR by producing clear, consistent contemporaneous documentary evidence of payment, title and removal to taxable persons.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal indicated that evidence consisting largely of second‑hand assertions without contemporaneous documentary support is insufficient in customs/VAT valuation and OSR contexts, and that commercial explanations (such as end‑of‑line or surplus stock claims) require documentary corroboration; market‑website comparisons (for example Alibaba listings) may be inadequate to rebut HMRC’s valuation methodology.