It is our intention to have products manufactured in Germany and moved/sold to customers situated in the UK. As the products are liable to a duty of excise within the territory of the EU, we understand that the goods may only be moved without payment of excise duty under the Excise Movement Control System (EMCS) procedure.
We believe that to utilise these procedures the receiving premises in the UK must be approved as an excise warehouse by HM Revenue & Customs (HMRC) and be allocated a System for Exchange of Excise Data (SEED) number relevant to the excise warehouse. Our issue is that our UK Ltd company is not physically based in the UK and the premises we will be using to receive the goods does not hold an excise warehouse approval and is not authorised as an authorised warehousekeeper.
I have contacted HMRC and it advised that, as we do not have premises within the UK, we cannot make an application for the UK warehouse to be approved as an excise warehouse and therefore it cannot be allocated a SEED number for the purpose of the EMCS system. This will make our planned business scheme expensive if we have to pay excise duty on the goods being manufactured in Germany. We wondered if you could review this and advise if what HMRC says is strictly correct and if there are any options available to us that will mitigate the costs?