Last minute changes to Brexit guidance

This alert, aimed at organisations trading in goods, sets out details of some recent changes to HMRC guidance in relation to the UK’s new trading arrangements once the Brexit withdrawal period ends on 31 December 2020.

During December, HMRC issued a number of new or changed guidance documents and several of these were issued in the week ending 18 December. The changes include:

• Confirmation that non-established organisations can operate a UK duty deferment account if they have a UK bank account and a full financial guarantee is provided.
• Some revisions to the UK Global Customs Tariff. From 1 January 2021, the UK will no longer apply the EU Customs Union tariffs and a new schedule of UK tariffs was published during summer 2020 – we understand that some revisions to the tariff have been made in recent days. Organisations that have been planning next year’s purchase or sales transactions should check that the tariff rates they have used remain the same. The UK Global Tariff can be accessed here.
• New guidance on trading with Northern Ireland under the Northern Ireland Protocol. This is an area that remains fluid and it is possible that further changes could be made, potentially at very late notice. The latest guidance can be accessed here.
• Organisations trading with Northern Ireland should consider signing up for the Trader Support Service and the UK Trader Scheme. When goods move from Great Britain to Northern Ireland, organisations will need to declare whether or not the goods are ‘at risk’ of onward movement to the EU (e.g. Republic of Ireland) and EU Customs Duties will need to be paid where this declaration is not made. If you import goods into Northern Ireland and want to declare your goods not ‘at risk’ so that EU duty will not be payable on those goods, you’ll need to apply for an authorisation for the UK Trader Scheme. Further information from HMRC is available here.

HMRC has issued a lot of updated guidance and it is proving a challenge for organisations to keep on top of the developments whilst making their best efforts to prepare for the UK’s new trading arrangements. Organisations are advised to review the latest HMRC guidance to see whether it has an impact on the plans they have put in place to give their products the best possibility of being able to move without disruption come 1 January 2021.

For more information, visit our Brexit Hub. If you would like to discuss this issue further, please contact Rob Marchant or your usual Crowe contact.