With the Brexit transition deadline looming, HMRC is now in the process of sending letters to all VAT-registered businesses within Great Britain that trade with the EU and/or the rest of the world.

The letter, which you can access through the following link, sets out the action businesses need to have taken in order to continue to trade freely with EU firms from January 1, 2021.

https://www.gov.uk/government/publications/letters-to-businesses-about-new-trade-arrangements-with-the-eu-from-1-january-2021

 

  1. Do I Need To Act Now?
  • YES!
  • It is really important that you act now – a free trade agreement will not remove any of the revised reporting requirements and unless you have all the correct processes, contracts and agreements in place you will not be able to trade with the EU from January 1, 2021.

 

  1. What Is Changing?
  • Businesses will need to make import and export declarations to move goods between Great Britain and the EU, as currently happens between the UK and countries outside the EU;
  • From 1 January 2021, if you send goods from Great Britain to customers in the EU, you will be responsible for completing export declarations for those goods
  • Firms that import controlled goods from the EU, such as animal products, alcohol or tobacco, or firearms, have to make declarations from 1 January 2021.
  • Businesses that import goods from the EU into Great Britain not on the controlled goods list, and have a good compliance record, have the option to defer declarations for up to six months, although you must still keep records of everything you import.
    • These import simplifications mean businesses will have a window to make supplementary declarations for imports, so you will not need to declare at port, as long as you have a good compliance record.
    • Authorisation is necessary to make the supplementary declaration and many businesses will use customs agents to do this
  • From 1 July 2021, all traders moving goods will have to make declarations and pay relevant tariffs at the time you move your goods.

 

  1. What Do I Need To Do?
  • Businesses that rely on others such as freight forwarding companies and fast parcel operators to deal with import and export declarations are advised to contact their partners to ensure they are covered.
    • By doing so, you are ensuring that you have everything in place by 31 December 2020, and to ensure you can continue to trade with the EU.
    • You need to ensure that details about your transactions, such as how your business imports or exports, and the type of goods, along with the quantity, customs value, and where the goods are going, is clearly understood by your agent if they are to deal with gaining authorisation to make supplementary declarations.

 

  1. What Are The Implications Upon Tariffs Payable?
  • The amount of tariffs due, if any, will depend on the value, category and ‘origin’ of the goods being moved.
  • Businesses will need to be familiar with these terms – unfortunately that may mean going beyond the procedural information contained within HMRC’s letter.
  • HMRC has previously said that import VAT does not have to be paid at the border if goods in a consignment do not top £135 in value.
    • The only exceptions will be excise goods and gifts.
  • New rates of customs duty for imports, the UK global tariff, are still to be introduced, while the free Trader Support Service (TSS) will handle the new processes arising under the Northern Ireland Protocol from 1 January 2021.
  • HMRC has committed to providing more guidance on changes to trade with the EU over the coming months.