On the 12 March the government updated its advice to traders with the EU. The advice assumes a no-deal outcome.
On the basis that being prepared for the worst possible outcome, and a no-deal result is universally accepted to be a disaster for UK businesses, we are reproducing in full the text of the letter in this post. Here’s what HMRC are advising:
Leaving the EU: actions for your business to take now to be ready for no deal
We are writing to you because you are VAT registered and currently import and/or export goods with the EU. This letter sets out actions that it’s important you take now and changes you need to be prepared for, in the event that the UK leaves the EU without a deal. The actions set out in this letter do not apply to importing and/or exporting goods between Northern Ireland and Ireland. The government will do everything in our power to avoid a hard border whatever the circumstances. We will write to you with information about this as soon as we can.
How to make customs declarations
You will be responsible for making customs declarations for your UK-EU trade in a no deal scenario. Many businesses find the simplest way to make customs declarations is to appoint a customs agent to manage the process for them.
So that you are ready you should now:
register for your Economic Operator Registration and Identification (EORI) number if you haven’t done so already at www.gov.uk/hmrc/get-eori. Then:
if you want to make declarations through a customs agent, appoint one as soon as possible.
If you cannot appoint an agent, or do not think this is the right solution for your business and if you intend to import or export regularly, you should now:
make sure someone in your business is trained to make customs declarations
buy specialist software that links to HMRC’s customs systems
if you’re exporting, register for the National Export System at www.gov.uk/guidance/export-declarations-andthe-national-export-system-export-procedures.
For further information, go to www.gov.uk/hmrc/trade-with-the-eu.
Making importing easier
HMRC is introducing new Transitional Simplified Procedures (TSP) for customs, to make importing easier for the initial period after the UK leaves the EU, should there be no deal.
Once you’re registered, you’ll be able to transport your goods into the UK without having to make a full customs declaration at the border, and you will be able to postpone paying your import duties. However, for controlled goods you will have to provide some information before import. Sign up for TSP online from 7 February at www.gov.uk/hmrc/eu-simple-importing. You’ll need an EORI number to do this.
For further guidance, including which ports TSP applies to, please go to www.gov.uk/hmrc/eu-simple-importing.
Changes to VAT
The way you account for VAT on imports will change. You will be able to pay import VAT in your next VAT return rather than when your goods arrive at the UK border. You will:
be able to declare and recover import VAT on the same VAT return
need to provide your VAT registration number on your customs declaration.
Further information will be available soon.
Changes to VAT IT systems
If the UK leaves the EU without a deal you will no longer be able to use certain EU VAT IT systems. If you currently use any of these systems, you should be aware of the following:
EU VAT Refund Electronic System
To make EU VAT refund claims for 2018 using EU VAT Refund Electronic System, you should submit these before 29 March 2019, instead of the normal deadline of 30 September 2019. After we leave the EU, UK businesses will be able to reclaim VAT from EU countries, by using the existing processes for non-EU businesses.
EU’s VAT number validation service (VIES)
If you use VIES to check a customer or supplier’s VAT number, UK VAT numbers will no longer be part of this service after 29 March. A UK-only online VAT number checker will be available on GOV.UK from 29 March. You will still be able to use VIES to check the validity of EU VAT numbers.
UK VAT Mini One Stop Shop (MOSS)
If you currently use MOSS to declare and pay VAT on sales of digital services to EU consumers, you should submit your return for supplies made between 1 January 2019 and 29 March 2019 via the UK portal by the normal deadline of 20 April 2019. If you want to continue to use MOSS for sales you make after the UK leaves the EU, you will need to register for MOSS in an EU Member State. You should do this by 10 April 2019. For further information, go to www.gov.uk/hmrc/eu-vat-it-rules.
Make sure you find out about all our EU Exit news as it happens
Register for our email update service at www.gov.uk/hmrc/business-support select ‘business help and education emails’, then ‘EU Exit’.
Non-VAT registered businesses should also go to www.gov.uk/hmrc/trade-with-the-eu for changes that affect them.
We recognise the challenges that you face in getting to grips with new and unfamiliar requirements by 29 March 2019. We are committed to supporting you and your business through this period of change, helping you to comply and making importing and exporting with the EU in a no deal scenario as easy as possible. We’ll write to you again soon, to let you know what further actions you’ll need to take and when.
Readers concerned that they cannot cope with the apparent complexities of the above should seek professional advice. Please call, we can help.