In this week’s EU exit corner, we feature HMRC’s response to our letter on the reimbursement scheme and the One Stop Shop, updated apportionment guidance for not at risk goods and guidance from HMRC on approvals and special procedures that may help simplify customs processing. HMRC is also seeking assistance with research and details of upcoming webinars for businesses importing and exporting are also provided.
Reimbursement scheme – HMRC responds to Institute’s letter
Last week, the Institute received a response from HMRC after seeking an update on when the duty reimbursement scheme will be ready for tariffs paid on “at risk” goods brought into NI from GB which are subsequently found to have stayed in NI. In its response, HMRC said that “work continues at pace to develop the scheme” but they are unable to give a definite date for when it is ready.
HMRC reminded readers that there “are a range of options available to allow traders to move goods into Northern Ireland without incurring tariffs and we encourage you to highlight these to traders. We have also recently launched a tool to help traders understand their tariff options when moving goods GB-NI. It can be found at https://www.gov.uk/check-tariff-goods-ni-from-gb.” HMRC are also keen to hear feedback on this tool.
We are aware of the cash flow and other implications of the delay in opening the reimbursement scheme and will continue to discuss this with HMRC and keep members updated.
Goods not at risk - HMRC’s apportionment approach
As previously advised, HMRC has developed an apportionment approach that allows businesses authorised under the UK Trader Scheme to declare goods “not at risk” based on the expected outcome for the goods, where the final destination is not known at the time the goods enter Northern Ireland.
For example, if you are bringing a consignment of goods into NI but at the time of import you do not know which item within the consignment will go where but you know that typically 60 percent of your goods move into the EU and 40 percent end up with end consumers in NI, you can declare 40 percent of the goods as “not at risk”. This is known as apportionment.
The guidance has been updated recently to provide additional content on reconciliation and evidence to support the apportionment used. Although the updated guidance has not yet been officially published on GOV.UK, HMRC has provided us with a copy to share with our members. Further functionality is planned by HMRC and the guidance will be updated once this is ready.
One Stop Shop Portal now operational
The EU’s VAT e-commerce rules changed with effect from 1 July 2021 and under the terms of the Protocol on Ireland / Northern Ireland, this affects NI businesses that sell goods to the EU.
The One Stop Shop (“OSS”) procedure is designed to enable businesses to register in one Member State and complete one return for all EU sales. This is a major simplification and negates the needed to register for VAT and submit VAT in potentially all of the EU member states that sales are made to.
Businesses that sell goods from NI to the EU are able to pay VAT to all EU countries through HMRC using the OSS. HMRC confirmed to the Institute in its letter last week that the system is now operational. Updated guidance is now available, which includes a link to the OSS portal.
Research request
HMRC is currently conducting research on the XI EORI application process. The main aim of this research is to:
- understand what problems are encountered whilst applying for an XI EORI using the current application process; and
- identify and negate any problems that may be present in prototypes of the new XI EORI application process, so that it will be easier to apply for an XI EORI.
HMRC is seeking to speak with people who have applied for an XI EORI either:
- for a company that they own/work for; or
- as an agent on behalf of a company
HMRC is running these research meetings from 12 to 23 July between 9am and 5pm. If you would be happy for your email to be provided to HMRC to take part in this research, contact brexit@charteredaccountants.ie who will pass this on to HMRC. HMRC will then contact you directly to find a suitable time for the research.
Customs processing
HMRC has sent the below information about some of the approvals and special procedures that may help simplify customs processing and reduce VAT and customs duty owed and where to go for more help. These may be useful if you are a business that usually re-imports or re-exports as part of your business process.
“1. Inward processing
This is a customs special procedure that allows you to suspend Customs Duty and import VAT on goods you bring into the UK for repair or as materials for manufacturing. You will not need to pay duty or import VAT on the goods if you re-export them following processing or repair.
For example, this may apply if you’re bringing your camera equipment into the UK from France for repairs with the intention of returning them to France. Or, if you’re bringing in fabric to be made into dresses which you will then export.
Find more information on using inward processing on GOV.UK.
Find more information on applying to delay or pay less duty on goods you import to process or repair on GOV.UK.
2. Outward processing
This allows you to temporarily export goods outside the UK for processing or repair and pay less Customs Duty and import VAT when you re-import them into the UK.
This may apply, for example, if you’re exporting a batch of computers to Germany to be repaired and returned to the UK. Or if you’re exporting bales of fabric to Romania to be made into prom dresses and then re-imported into the UK.
Find out more on using outward processing on GOV.UK.
Find more information on applying to pay less duty on goods you export to process or repair on GOV.UK.
Q3. Temporary Admission
This is a special procedure that allows you to temporarily import goods into the UK or move goods from Great Britain into Northern Ireland without paying Customs Duty or import VAT. You may use the goods for up to two years or more, before re-exporting them.
For example, this may apply if you’re temporarily bringing in samples, professional equipment or items for auction, exhibition or demonstration into the UK.
You can apply for Temporary Admission if you’re the person using the goods or you’re arranging for the goods to be used on your behalf.
Find more information on how to apply to import goods temporarily on GOV.UK.
Q4. Returned Goods Relief
This allows you to claim relief from Customs Duty and import VAT if you’re re-importing items into the UK that have previously been exported. When you re-import your items, you’ll need to make sure they’ve not been altered, apart from work to maintain them.
This may apply, for example, if you’re re-importing office furniture, equipment or instruments because you’re moving back to the UK from an EU country where you previously exported the goods to.
Find out more on paying less import duty and VAT, when re-importing goods on GOV.UK.
Q5. Customs warehousing
This allows you to suspend Customs Duty and VAT on goods that you import into the UK and store in a warehouse to be re-exported. Duty and VAT will only become payable when the goods are removed from the warehouse into UK circulation.
For example, no duty or VAT will be payable if you import children's toys from China to be stored in a warehouse in the UK before being re-exported to Portugal.
Find out more information on how to use a customs warehouse on GOV.UK.
Q6. How would I know which approvals and special procedures I need?
If you’re using an intermediary to move your goods, they may already have approvals and special procedures in place that you can make use of. You should check this with your intermediary.
To find out more, go to our simple online trader tool where you can check what options are available and most suitable for you.
Q7. Where can I find further help and support?
More information on where to watch videos, sign up for email alerts and register for webinars to learn more about UK transition can be found on the help and support page on GOV.UK.
Watch the video on how to use the online trader tool and our other short videos on HMRC's YouTube channel to familiarise yourself with customs processes and what you need to do before trading goods with the EU.
To ask and get answers to specific questions about HMRC processes for importing or exporting, please visit our customer forums.
Give us a call
Our customer service advisors are available to answer your queries on the Customs and International Trade helpline. They’ll help you with importing, exporting and customs reliefs. The helpline is open from 8am to 10pm Monday to Friday and from 8am to 4pm at weekends. Call 0300 322 9434 to speak to an advisor.
We will continue to provide guidance and support to help you and your business, including information on GOV.UK, our popular live webinars and through this weekly email.
If you know of a business who would also find these weekly emails helpful, please forward it on, or suggest they register to get these updates directly to their inbox.”
Webinars
Importing – steps you need to take before making your supplementary declaration
To support those who’ve delayed their customs import declarations, HMRC explains in this webinar the actions you need to take before you can make a supplementary declaration and how intermediaries can help you do this.
Please register to take part if your clients have imported goods since 1 January 2021 and not yet completed a customs declaration for them.
If your clients are planning to import and you want to understand the full declarations process, please register for Customs Import Declarations: an overview.
Exporting: what you need to do to keep your goods moving
This webinar is an overview of the actions to take now when exporting goods from Great Britain to the EU and moving goods between Great Britain and Northern Ireland. Key processes include zero-rated VAT, customs declarations and using an intermediary in addition to licences, certificates, and authorisations.
Please register to take part if you’re planning to export.
Trader responsibilities when using an intermediary
This webinar explains your client’s responsibilities as a trader if they choose to use an intermediary to complete import or export declarations for their business. These are complex and an intermediary can save a lot of time.
Please register to take part if you’re planning to import or export.
Rules of origin
If your clients buy goods from the EU or send or sell goods to the EU for their business, this recorded webinar will help them understand rules of origin and what’s required to meet the rules. It can be paused or rewound to allow you or your clients to work through the information at your own pace.
Watch the recorded HMRC webinar