VAT Director Rayner Essex
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Postponed accounting: Your questions answered

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Four months after Brexit changed the UK VAT regime, Jason Croke tackles some of the queries raised about postponed accounting in the Any Answers forum.

7th May 2021
VAT Director Rayner Essex
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As we move into May, a good four months into Brexit, we now have some experience with postponed VAT accounting.  The variety of questions posed about the issue in the Any Answers section indicates that there are a lot of real life scenarios out there that are causing confusion. This article offers some answers to some representative examples.

Question 1: “I don’t know where to access the Monthly Postponed Import VAT Statements (MPIVS).” 

Logging into your government gateway does not give you access to the MPIVS, it seems you need to log in via a specific GOV.UK postponed accounting link and then log into your government gateway, Bookmark the link so you can get back to it.

Don’t forget to download your MPIVS or print them out, because they are only available online for six months. 

Question 2: “I haven’t paid any import VAT and not had any paperwork from HMRC or freight agent.”

Some freight agents default to using postponed import VAT accounting, even if you’ve not asked them. So if you’ve not done so already, enrol for the online Customs Declaration Service (CD). You will then receive a monthly reminder email and link to log onto your gateway and find your MPIVS. So even if you didn’t ask and your freight agent assumed you want to postpone, you will not be in the dark as the monthly email reminder will prompt you to log in and capture any import VAT that you didn’t know about.

As the MPIVS only stay online for six months, the scenario could arise where you are not aware you are postponing VAT and when you do realise and enrol for the service, those earlier statements may no longer be visible. So do check sooner rather than later that you have access to CDS/MPIVS before it is too late.

Question 3: “The invoice from the EU supplier has no VAT on it, do I reverse charge like before?”

If the invoice is for services, then you do still reverse charge those invoices as you did prior to Brexit. But if the invoice is for goods from the EU, then we no longer reverse charge.

Imports where the freight agent pays the import VAT at the dock/port or where you have a deferment account, then you will receive a C79 in the post from HMRC and this C79 is your document to reclaim the VAT.

Imports where you are using postponed import VAT accounting – whether by request or freight agent assumption – then you use the government gateway to access your MPIVS.

It is important to remember that unless you are using the same freight agent every time, that your imports will be handled by different couriers and freight agents and unless they are instructed beforehand, then some will default to postponed import VAT accounting, some will just use their own deferment account and recharge you and the C79 will arrive in the post afterwards.  The takeaway here is that your accounts team need to be aware of these two different ways in which VAT can be treated on imports and they need to know the difference and when to use the appropriate VAT codes.

Question 4: “I was expecting a C79 but have not received it in the post as yet?”

First check your paperwork, the freight agent may have defaulted to postponed VAT without telling you. C79s are sent in the post and so it is possible for them to get lost in the post, you can request copies from HMRC.

Question 5: “How do I account for import VAT in my accounting software?”

Different software has different ways of dealing with import VAT, remember that import VAT can be paid by freight agent/deferment and then reclaimed afterwards (C79) or by postponing (MPIVS).

For a fully taxable business that can reclaim all input tax, it is still important to be get the coding/data entry correct, because you still need to ensure you are compliant for Making Tax Digital (MTD) purposes. Remember that MTD will apply to all VAT registered businesses from April 2022.

For businesses which are partially exempt, it is especially important to get the VAT coding correct, as a partially exempt business may not be able to reclaim all of the VAT it incurs, including import VAT. Speak with your cloud software providers for an update on what coding to use.

Brace for Brexit hub

Some of the frustrations relating to Brexit have been around having to do things differently, but hopefully this article has answered some of your questions. 

Some of these points and many others are covered in more detail on AccountingWEB's Brace for Brexit hub.

Replies (8)

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By GTH
12th May 2021 11:38

My PVA reports HMRC have issued have been confusing to say the least and are summarised as follows:
Jan report produced 06.02.21: All entries identified as Jan
Feb report produced 06.03.21: Some Jan entries repeated along with all Feb entries
March report produced 07.04.21: Some Jan entries repeated but no March entries

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By Wanderer
12th May 2021 13:39

Can't find any Postponed import VAT statements. Logging on to the correct link, as given by Jason, shows the correct EORI number but always:-

"There are no statements available to view yet."

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By lavalamp
12th May 2021 15:31

I've been unable to register for the Customs Declaration Service. I've double checked all the information I'm using is correct, I've spoken to the Vat helpline who have confirmed it's correct and have told me to email the CDS operations team. I sent the email 6 weeks ago and have had nothing back. Ridiculous state of affairs.

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Replying to lavalamp:
Jason Croke
By Jason Croke
17th May 2021 12:11

It's usually the postcode/address that causes the problem, must be exactly the same as per your VAT certificate.

The CDS email address is [email protected] and their number is 0300 3229434. I have come across a few scenarios where the automated CDS registration system just doesn't seem to work, had a couple myself.

Thanks (1)
Jason Croke
By Jason Croke
17th May 2021 12:06

HMRC have confirmed there were some problems with the PIVA statements in Jan/Feb and that there are still some gremlins in the system.
https://www.gov.uk/guidance/complete-your-vat-return-to-account-for-impo...

My initial thought is, if you're seeing "no statements available to view", then go back to basics and check the following :-

1. Has freight company got your GB EORI, no typos or transposition of numbers?
2. Is the supplier using your GB EORI or are they using the end customers GB EORI (in the scenario where you are ordering goods from your EU supplier and having delivered directly to your UK business customer (B2C).
3. Has your freight agent been told you are using postponed import VAT accounting? if they are not told, they will default to paying the import VAT for you and recharging that to you as an invoice, followed by a C79 from HMRC 45 days later.
4. HMRC could just be terrible and your goods have slipped through the net for some reason.

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By jamesmarson
07th Jun 2021 09:57

I thought that all the gremlins had been resolved, but then logged in and saw "There were no statements in May" on my account... which doesn't make sense based on my knowledge of transactions. Has anyone else noticed any issues with the May statements; i.e. whilst they were expecting a statement, they're getting the message that there are none?

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Replying to jamesmarson:
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By Jamie M
08th Jun 2021 09:55

Yes same here. I am expecting the statement but saw "There were no statements in May" Today. could that be they have not uploaded the statements to the site?

I am also aware the statement from Jan to Apr do not match the import data which provided from the logistic firm who does import clearance on behalf of us. has anyone also has the same issue ?

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Replying to Jamie M:
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By jamesmarson
11th Jun 2021 09:33

My May statements have now been published on the HMRC portal. It must have been an issue that’s now been resolved.

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