05 September 2019
At the time of writing (and in spite of conversations in parliament this week) the UK is scheduled to leave the European Union at the end of October.
With many questions still to be answered, Angela Appiah Shippey, Client Services Director at FD Works, sat down with Brexit expert Katrina McWhinnie to discuss the latest developments.
Angela – Thanks for taking the time to talk to us today. In the last few weeks we’ve seen the government ramp up no-deal preparations by automatically enrolling VAT-registered businesses with EORI numbers.
One of the questions to emerge since this announcement is whether smaller firms who send low-value items through the standard postal system need an EORI number? For example, will an Etsy seller posting £50 handmade jewellery to a customer in an EU country need to apply?
Katrina – My understanding is all businesses who import or export will need an EORI number. Whilst HMRC wrote to easily identifiable, VAT registered businesses who trade with Europe, it’s anticipated that a further 95,000 businesses that aren’t VAT registered will also need an EORI number.
You will need a UK EORI number to engage with UK customs processes and an EU EORI number to engage with EU customs processes. An EU EORI number is obtained from the customs authority in the EU country you first conduct trade with or that you request a customs decision from. An EU EORI number would only be required in a situation where the sale contract provides that either the buyer or seller are responsible for both import and export declarations or in a scenario where the UK business has a branch in the EU and exports from the UK to the EU branch, it would be responsible for making both import and export declarations. You won’t need a duty deferment account (DDA) if you only have import VAT to pay and are registered for postponed VAT accounting. You will need a DDA if you have duties and taxes to pay or are not VAT-registered. You can view customs duties to pay by checking the no deal tariff schedule.
Small businesses who use fast parcel operators (FPOs) such as TNT, UPS or Yodel and have been approved by HMRC to use bulk export procedures using a memorandum of understanding can bulk declare your items for Customs Export entry purposes, if the value of goods you are selling is less than £873 and non-restricted. Where goods are over £873 in value, restricted or subject to a licence, regardless of the value, there must be a full customs entry providing official and commercial proof of export. If you use a FPO and they complete your customs entries on your behalf, it is essential you provide clear written instructions for the goods to be entered for the particular relief concerned; clearly identify the person claiming the relief and ask them to send you details of the customs declarations made on your behalf so you can check the accuracy.
Businesses involved in consultancy or services will not require a EORI number, unless the services involve moving tangible goods in and out for repair. You do not need an EORI number if you only move goods between Northern Ireland and Ireland.
Angela – Thanks for clarifying Katrina. Any other tips you can share for businesses (VAT-registered and sole-traders) likely to be impacted?
Katrina – Under import rules for trading with the rest of the world, goods will not be released from customs control until you’ve made a full import declaration and paid customs duty in full. If your business is UK VAT registered, you’ll be able to account for import VAT on your VAT Return, meaning you don’t have to pay when the goods arrive at the UK border, cushioning any cash flow problems. If you do not have a UK VAT registration, you will need to pay import VAT at the time you import the goods.
For many businesses, applying for a Transitional Simplified Procedure (TSP) can be a good step, as it enables them to delay submitting full declarations and payment of import duties by up to 30 days. When doing this the business owner may need to arrange a duty deferment account and set up a direct debit to honour payments.
On this point, it’s worth mentioning that approval is required (so a healthy background is essential) and that the arrangement is only temporary.
When exporting goods to the EU under a no-deal Brexit, similar trade rules will apply to outside trade with the rest of the world. It is important businesses check whether a licence is required or any special rules apply when exporting to overseas markets. Refer here for further details.
Angela – Amazing, thanks Katrina.
Katrina – No problem at all. Something else that’s worth mentioning is the collaboration between the Institute of Export & International Trade and HMRC to provide customs training. The government has announced new grant funding providing up to 100% of the cost of training your employees, limited to £2,250 for each course. This will help businesses better understand the customs process and complete customs documents more efficiently. Those interested in training can apply for a grant to do so here. The grant has been extended to recruit employees to complete customs documentation.
Angela – perfect, thanks for your time.
Katrina McWhinnie is a Brexit Strategist and founder of the McWhinnie Consultancy. For more information or to speak with Katrina directly, please visit – themcwhinnieconsultancy.uk.
Angela works as the Client Director for FD Works, a team of accountants, business advisors and Xero specialists located between Bristol and Bath.
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