It’s been over 2 years since the UK invoked Article 50 of the EU’s treaty and began formal proceedings to leave the European Union. The recent changes in Government has led to increased media speculation that leaving the EU without a deal is a real possibility. Whilst there is still little in the way of definitive information about the implications of this from a VAT and Customs perspective, there are measures that can be taken to ensure you’re as prepared as possible.
HMRC have recently updated its draft of notices setting out certain legal requirements of a new standalone regime in the event of a no-deal Brexit. The notices are currently indicative but would come into force before exit day which is currently planned for 31 October 2019.
The notices cover the rules relating to the importation of goods into the UK under a stand-alone Customs regime and contain information on all aspects of importations including:
- Information to be provided on electronic declarations and temporary storage arrangements;
- Procedures to use simplified customs declarations;
- Forms of payment to HMRC to discharge import liabilities;
- Applications for approvals, authorisations and AEO status;
- Evidence required in relation to valuations of goods; and
- Applications for remission or repayment of import duty
A full list of the draft notices can be found here.
Advice has also been released by the European Commission – which is currently preparing for a ‘no-deal’ scenario – and advises businesses and their stakeholders to prepare for all outcomes, encouraging them to take advantage of the 6-month extension granted in April to implement necessary precautions.
In their most recent discussions, the Commission detailed a number of areas that need to be particularly vigilant in the next few months to prepare for a no-deal Brexit, including:
- Citizens’ residence and social security entitlements
- Medicinal products, devices and chemical substances
- Customs, indirect taxation and border inspection posts
- Fishing activities
- Financial services
It’s still impossible to interpret the full implications of a no-deal Brexit, and many questions still remain such as how it may affect overseas trade, how the movement of goods to and from the UK will be affected or the impact on supply chains, but it is important to remain informed and implement appropriate Brexit contingency measures sooner rather than later.
To help with this, the government has provided comprehensive information for businesses that currently trade with mainland Europe and want to continue sending goods from the UK to the EU in the event of a no-deal Brexit, which can be viewed here.
At Smith Cooper we have a dedicated VAT and Customs team who will ensure you are continually updated on any issues that may arise though Brexit proceedings, and the implications they may have.