As the prospect of a “no deal” Brexit becomes more of a possibility, businesses who move goods between the UK and European states need to consider making contingency plans.
At present all movements of goods within the EU are in “free circulation”. However, in the event of a no deal Brexit, any movements of goods between the UK and the EU will be the same as with non EU states. All goods coming into and going out of the UK would be subject to the same rules and procedures. Goods coming in from the EU will need to be cleared through Customs with the VAT and duty paid, while goods heading to the EU will need proof of export etc.
In order to be able to move goods into and out of the UK, businesses will need to be ready. Firstly, businesses will need to obtain and use an EORI number. This is quoted on all documentation relating to imports and exports. You can apply to get an EORI number by clicking HERE.
Secondly, all movements of goods into and out of Europe are currently recorded and processed on a Government system called CHIEF. This contains information relating to each movement of goods and calculates any VAT and duties due. For a number of reasons CHIEF is being replaced by a new system called CDS. Notwithstanding this, in the event of a no deal Brexit all imports and exports to the EU will also need to be reported and processed via CHIEF / CDS. The majority of CHIEF reporting is handled by agents and as such, if a business has an agent, they will ordinarily take on the EU movements as well as the CDS reporting when it replaces CHIEF.
Most businesses potentially affected by a no deal Brexit can appoint agents – at least in the short term – to clear goods and handle all the new reporting requirements. However, in addition to EORI registration, businesses can consider the following measures to alleviate the additional burden.
Set up VAT & duty deferment arrangements as well as simplified VAT import accounting. This would enable businesses to clear goods more quickly and pay the import VAT on periodic statements. This would smooth the process but would require staff to administer.
Set up VAT / Duty warehousing. This is a scenario whereby businesses set up a secure area where goods are imported and stored. Legally these goods are still “airside”. However, businesses have control, and can “clear” them into the UK (using the procedures used for normal importation) as and when they remove them from the secure area.
HMRC have extremely tight rules for operating these so it may only be something to embark upon if the “no deal” becomes a certainty.
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