Caselaw Digest
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Electric Mobility Euro Limited & Anor v The Commissioners for HMRC

[2024] UKFTT 590 (TC)
A tax court decided whether imported mobility scooters should be taxed. The court decided they were designed only for people who have trouble walking, so they didn't need to pay tax because they're considered aids for disabled people, not normal vehicles.

Key Facts

  • Appeal concerned customs classification of imported mobility scooters.
  • Competing classifications: heading 8703 (vehicles for person transport, 10% duty) or heading 8713 (carriages for disabled persons, duty-free).
  • Importations by Electric Mobility Euro Ltd and Sunrise Medical Ltd between 2016-2020.
  • Appellants argued for classification under heading 8713.
  • Case involved review of previous Invamed litigation concerning mobility scooter classification.
  • Commission Regulation (EC) No 718/2009 considered for potential analogous application.

Legal Principles

Decisive criterion for customs classification is the goods' objective characteristics and properties, as defined in the CN.

Invamed CJEU at [18] and [22]

Intended use is an objective criterion if inherent to the product and assessable based on objective characteristics.

Invamed CJEU at [22]

Marketing literature and manuals are part of objective materials for tariff classification.

HMRC v Honeywell Analytics [2020] EWCA Civ 243 at [127] and [130]

"For disabled persons" in heading 8713 means solely for persons with a non-marginal limit on walking ability.

Invamed CJEU at [27], [34]

Classification regulations are binding and may be applicable by analogy to similar products, but great care is needed.

VTech Electronics (UK) Plc v HMRC [2003] EWHC 59 (Ch) and Anagram International Inc (Case C-14/05)

Application by analogy of a classification regulation is unnecessary if the CJEU has provided all necessary information for classification.

Stryker EMEA Supply Chain Services BV (Case C-51/16) and subsequent cases

Outcomes

Appeal allowed.

Imported mobility scooters were designed solely for persons with a non-marginal limit on their walking ability, based on objective characteristics. The 2009 Regulation was not applicable by analogy.

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