HMRC webinar: Getting ready for Brexit
Neil Warren reviews key issues raised by HMRC’s ‘Getting ready for a no-deal Brexit’ webinar, including customs duties, customs declarations and entry summary declarations.
I was pleasantly surprised to learn from the webinar presenter that 82% of imports of goods from the EU to UK will have a zero-duty customs tariff in the event of a no-deal Brexit. However, this will be a temporary situation for the first 12 months.
This does not mean that the same level of low duty will apply when UK goods arrive in other EU countries. There will be no ‘export duty’ when the goods leave the UK – quite rightly so! Goods might still be subject to excise duties when they arrive in the UK, for example alcohol and tobacco.
Entry Summary Declarations (ESD)
These declarations will not apply to EU imports for the first 12 months after Brexit but will continue to be relevant for non-EU imports of goods. This time period is to help businesses adjust to the new procedures. The declarations must be submitted before goods arrive in the UK once the transition period has ended. They have not been necessary in the past because of our EU membership – only for non-EU imports.
Important point: Importers will still have to submit import declarations for customs purposes in the transition period, which are not the same as an ESD.
Transitional Simplified Procedures (TSP)
This procedure is intended to simplify imports of goods from EU countries for ‘at least a year’ (to quote the presenter) after we leave the EU. It is easy to register for TSP and it will reduce the information needed when goods are imported.
The main practical benefits are that hauliers will be able to transport goods into the UK without making a full customs declaration at the border, and will be able to postpone paying any import duties. HMRC will review the scheme after three months.
Important point: TSP will apply to goods coming into the UK via Dover and the Channel Tunnel, plus other UK ports depending on circumstances. Before applying for TSP, a business must have a UK EORI number. HMRC will refuse a TSP application in some cases eg if a business is insolvent or has a bad compliance record.
The webinar highlighted that a business must decide whether to use professional help to deal with customs declarations eg third party freight forwarders, import agents to clear goods, or to deal with them internally. The freight forwarders can arrange customs clearance using their software to deal with the HMRC system. Import declarations will be based on the Single Administrative Document (C88 form).
Important point: If a business decides to deal with the declarations internally, using the TSP procedures considered above, it must have the right software in place and must also have a duty deferment account. Excise and customs duties will then be paid by direct debit, as well as VAT for businesses not registered for VAT ie which cannot take advantage of postponed accounting.
Staff training budget
To quote the presenter, grants are available to help with staff training for ‘businesses that complete customs declarations.’ The deadline date for claims is 31 January 2020. In some cases, funding can be given for computer improvements necessary to deal with the new rules.
The end result will be that imports from the EU will eventually go through the same controls and procedures as we have had for many years with non-EU imports. In other words, there will be no difference buying goods from France or China.
But before we get to that outcome, there are some important transitional opportunities that businesses may need to utilise if appropriate in order to make life easier... if only a little easier!