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Anjum Shabbir
Anjum Shabbir
9th October 2020
External Relations & Trade Internal Market Tax

Analysis: “The extinguishment of a customs debt incurred through non-compliance: mitigating the impact of formalism in customs” by Philippe Heeren

The Court of Justice clarified in its Combinova judgment of 8 October 2020 (C-476/19) when goods are ‘used’. This is relevant to assess whether a customs debt, incurred as the result of non-compliant behaviour, could be extinguished on the ground that the goods ‘have not been used or consumed and have been taken out of the customs territory of the Union’ (Article 124(1)(k) Union Customs Code). The Court concludes that this use refers to operations other than those that are authorised by the customs authorities under a special procedure.

Combinova imported goods under the inward processing procedure. With this procedure, Swedish customs authorised the company to process goods in the customs territory of the Union without having to


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