There is now a requirement to declare all goods exported from / imported into the UK.
The general procedures are fundamentally those that were in place before Brexit to handle exports and imports to/from non-EU states.
There are, however, interim arrangements available for EU imports until 30 June 2021 such that an entity importing standard goods can record them in its own records and make a supplementary declaration up to 6 months later. Initially, therefore UK businesses will not necessarily need to submit an entry summary declaration for their imports from the EU, though this will be preferred.
A VAT-registered entity (or its agent) will, however, still need to have the following in place before they can make that supplementary declaration:
- An EORI number
- Authorisation to use simplified declarations for imports
- A CHIEF Badge (Customs Handling of Import and Export Freight)
- Software that works with CHIEF
- A Duty deferment account for paying any import duties and VAT
If these are already in place, then complete compliance with the new regime can be ensured.
Businesses were given time/remainders to get these in place before 31 December 2020. All are required to ensure maximum flexibility in handling imports/exports and to apply PVA correctly under the new arrangements.
For ‘controlled’ goods and goods in ‘bond’, the already extant UK rules for making an import declaration will continue to apply.
Import VAT that is now being postponed is now being captured on a new Monthly Postponed Import VAT Statement (MPIVS) that traders need to access and download, rather than on the pre-existing online monthly statement (C79) available to businesses to download relating to their non-EU imports and exports. Copies of both of these should be kept for your records.
The MPIVS statement shows the total Import VAT postponed for the previous month. When received, it should agree (and be agreed) with the related transactions as already included in your records (if calculated correctly by the entity).
Whilst sales to the EU generally remain zero-rated, all businesses using the PVA scheme must (as at present) notify their EU customer that the customer is responsible for accounting for the VAT to the local tax authority using the ‘reverse charge’ rules. Each EU country has a threshold for such sales (individual and/or combined sales) that, once passed, means the UK business must itself register for VAT in that country. The selling business should also ensure they continue to meet the pre-existing evidence requirements for zero-rating exports.
If you are an MTD-mandated business, please remember that it is no longer possible to enter the summary information required for the VAT Return manually into the software that will submit that Return. All VAT-registered entities will need to make any required adjustments as part of their underlying record-keeping before this data is imported into the part of the software that prepares and dispatches the VAT Return to HMRC.
In Practice
There are some temporary relaxations in the border regime for bringing goods into the UK. These will apply until 30 June 2021. Nonetheless, in essence for goods to get into the UK, or get into the EU from the UK (except in Northern Ireland but only where the goods brought in are staying in Northern Ireland) all the paperwork will need to be in order. If it is not, goods will be stopped at the border.
Goods will not be released until after they have been inspected, paperwork has been put in order and any excise duties, fines, storage costs etc. have been paid up front.
Over half the UK’s individual transactions concerning non-bulk trade imports/exports in 2020 represented movements within the single European market. Given high levels of unfamiliarity with the existing systems, staffing constraints, Covid and a general shortage of expertise, border delays were expected for 2021.
Such delays have been seen, though they have been mitigated by reduced commercial movements and an almost total absence of leisure traffic at British and European ports of entry. These arise directly from Covid restrictions.
The required processes at the ports, however, still take much longer to complete than they did before Brexit even when importers and exporters arrive with all their paperwork in apple-pie order.
This article is limited to the key elements of the changes. It is not a comprehensive guide, nor is it intended to be. You are advised to consult with your professional advisor and to review the government’s own documentation on the matter.
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