As we approach the Brexit deal (or no deal) companies are being informed of how they need to prepare, one of these preparations is for companies which trade goods or services within the EU. As a company, you need to prepare for the possibility of us having a “no deal” with Europe, which will be decided by 29th March 2019.
The Economic Operator Registration and Identification (EORI) number is a number your company must have to enable you to import or export goods with Europe. This is not required for Ireland or Northern Ireland, as the government is working hard to prevent a hard border between our countries. If there is no deal with Europe, then you must have this number for your company to continue to import and export with the European countries, from 29th March. As you can see, this is a very short deadline to have the registration completed, so we do advise you do this as soon as possible.
As a company, you will be responsible for making your customs declarations for the trade between the UK and EU in a no-deal scenario. As a business, you may wish to appoint a customs agent to assist you (this is often the simplest process), if you wish to do this you need to appoint one as soon as possible so your company is ready from the day the decision is made between the EU and UK. If you cannot, or if you think that an agent is not the right solution, and you intend to import and export regularly, then you will need to:● Train a member of your team to make customs declarations● Buy specialist software to enable you to link with HMRC’s customs systems so you can declare all trade● If you are exporting, you need to register for the National Export System
The HMRC are introducing new Transitional Simplified Procedures (TSP) for customers to ensure importing is easier for the initial period after the UK leaves the EU, if there is a no deal Brexit. You will need to register to enable you 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, if you are trading controlled goods, you will have to provide extra information before import. You must sign up for TSP to utilize this easier process and to register you must have your EORI number. There are also changes to the way in which you will account for VAT on imports, where you will be able to pay import VAT on your next 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, and you will need to provide your VAT number on your customs declarations.
In the case of a no-deal Brexit, there will be some rather big changes to the IT systems we use within HMRC for EU VAT, for example, the EU VAT Refund Electronic System. If you wish to make EU VAT refund claims for 2018 using this system, you must submit your claims before 29th March 2019 (rather than the normal deadline of September 2019). After we leave the EU, businesses in the UK will be able to reclaim VAT from EU countries by using the existing processes for non-EU businesses. The EU’s VAT number validation service will no longer be able to check a customer or supplier’s VAT number if it is for the UK, and the service will be stopped after 29th March. A UK-only VAT number checker will be available from 29th March and you will be able to use VIES to check the validity of EU VAT numbers using the service.If you currently use the UK VAT Mini One Stop Shop (MOSS) service to declare and pay VAT on sales of digital services to EU consumers, you need to submit your return for supplies made between 1st January and 29th March 2019 via the UK portal, by the normal deadline of 20th April. If you do wish to continue to use MOSS for your sales you make after we leave the EU, you will need to register for MOSS as an EU Member State by 10th April 2019.As you can see, there are a lot of potential changes coming in for VAT registered companies, should there be a no-deal Brexit on 29th March 2019, the most important part of this process is to ensure you have your EORI number as soon as possible. This process can take up to 3 days, so if you wish to ensure you have the number prior to the Brexit discussions you need to do this before 26th March (and we recommend doing it sooner, to prevent the backlog delays that may occur).
