The appellant, Parul Malde, appealed against a series of assessments and penalties totalling £25m, which were raised by HMRC in 2015.

HMRC alleged that Malde had smuggled and sold alcohol in the UK between 2004 and 2014 via two overseas companies, Sintra SA and Sintra Global.

A series of assessments and associated penalty notices were raised by HMRC in 2015 against Malde, which alleged he was a director of both businesses.

Malde argued that that he was neither a director nor a shadow director of the companies, and that there was little evidence that either company had ever traded in the UK, therefore it could not be liable to UK VAT and excise duty payments.