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Updated ‘no deal’ Brexit guidance for moving goods between the UK and EU
Robert Marchant, Partner, VAT
In late March 2019 the UK government announced further details of measures to support businesses with new customs requirements should the UK leave the EU without a Brexit ‘deal’. The new measures are relevant to anyone who will move goods between the UK and EU and vice versa.
Extension of Transitional Simplified Procedures (TSP)
TSP is a UK simplification introduced by HMRC in recognition that many businesses may be new to import declarations given they were not previously required for movements of goods between the UK and EU. In the event of a ‘no deal’, goods from the EU will need to be imported into the UK and this requires the completion of an import declaration.
TSP allows businesses to transport goods from the EU into the UK without having to both make a full customs declaration and pay any import duties due at the time of the goods’ entry into the UK.
The newly announced measures include the following changes to TSP:
For goods imported up to 30 September 2019, an extension of the date when the first customs declaration must be submitted, and any import duties paid, to 4 October 2019, with subsequent declarations submitted monthly.
TSP to be available at all UK ports, not just Roll-on-Roll-off ports such as Dover per the original provisions.
UK Import guarantees
HMRC is also giving importing businesses until 30 September 2019 to provide a guarantee that is required to cover any customs duties payable in the UK that they wish to defer. This is applicable to all importers, not just those registered for TSP.
This is again a recognition by the government that many businesses will not have had to make imports before and so will not have in place the relevant guarantees needed for customs duty deferral arrangements such as Duty Deferment.
Importing into the EU
The measures noted above apply for goods being imported into the UK. Businesses that ship goods into the EU will also need to consider the requirements in the EU destination countries. The goods will need to be imported into the EU and import taxes paid.
A key point for consideration is whether or not the UK seller will import the goods into the EU destination country, or whether the customer could do so. This has not previously been an issue for sales of goods from the UK to the EU but becomes relevant in the event of a ‘no deal’ Brexit. UK businesses may therefore need to: register for VAT in the destination EU country, apply for an EU importer number, complete customs declarations in the EU country of importation, appoint local representatives if they do not have an office in the destination country.
UK companies shipping goods to EU countries should review what EU VAT and customs requirements they may have as there can be a lead time in putting in place local registrations/ approvals etc as well as understanding whether any additional costs, such as import taxes, may arise.
Checklist of preparatory steps
Register for an Economic Operator Registration and Identification (EORI) number. This is your importer number and is required to be able to import goods into the UK. In February 2019 HMRC estimated that just 17% of businesses that needed to register for an EORI number had done so.
Register for TSP to benefit from simplified procedures for UK imports.
For imports into the UK to be made after 30 September 2019, arrange a bank guarantee should you wish to operate Duty Deferment.
Liaise with your freight agent to check whether they will require any changes to your existing processes or information that you give to them. This is an important step in minimising any unexpected delays with your product movements.
For imports into the EU, understand whether any EU VAT and customs requirements may arise in the destination country.
How we can help
Businesses are having to deal with a significant amount of uncertainty and change. Crowe’s team of specialists can help you with reviewing your legal and physical supply chains to understand the impact of a ‘no deal’ Brexit on your business and/or can assist you with applying for measures such as TSP or an EORI number.
Partner, VAT and Customs Duty services
+44 (0)20 7842 7383
Read Robert's full CV