Beginning to export — VAT implications

19 July 2019

I am a small retailer specialising in bespoke leather goods, and all sales to date have been within the UK. In order to expand my customer base, I’m launching a website and planning to sell through Amazon. Are there any VAT consequences I need to consider?

Merchandise in Baggage

12 July 2019

I have the following questions on Merchandise in Baggage (MIB). If someone is carrying goods covered by an export licence, either a Standard Individual Export Licence (SIEL) or an Open General Export Licence (OGEL) and they do not declare the goods to customs on leaving the UK, is this illegal? Also, what if the goods are being supplied to another country within the EU, does anything change?

Preference certificate for Turkey

5 July 2019

We are considering buying in a wholly UK manufactured product on an exclusive marketing contract to sell alongside our existing export products. The product is manufactured in the UK and the company has issued a letter stating that the goods are of UK origin to cover us if we need to issue a Certificate of Origin for overseas customs purposes. But how do we use this in the event of issuing a preference certificate, eg EUR1 Preference document or ATR Form for Turkey? Will we need to determine our supplier’s value build-up of the selling price of the goods or can we take our ExWorks selling price to establish the goods qualify for preference?

EU-Japanese Free Trade Agreement preferential rate of duty

28 June 2019

We receive goods from a supplier in Japan and, even though the EU-Japanese Free Trade Agreement (FTA) came into force in February 2019, on reviewing our customs duty payments we have not been claiming the preferential rate of duty. We have spoken with our supplier who has confirmed that the goods do qualify under the terms of the FTA and they will start quoting the statement of preference on the invoices going forward but I wondered if we could apply for a refund of duty from HMRC on the shipments received since February 2019.

Forthcoming changes to the Incoterms ® Rules

21 June 2019

We understand that the International Commercial Terms (Incoterms ® Rules) are being updated and a new set is being published later this year, Incoterms 2020 we believe. Do you have any information on what the changes will be? Should we be concerned about new terms being introduced and start reviewing our contracts with the intention of updating our Incoterm ® Rules clause? I have read that there will be a new term included in the set and some specific terms for UK-EU trade.

Evidence of exports made outside of the EU

14 June 2019

We have been advised of a HM Revenue & Customs (HMRC) audit in the UK and have been told that we need to ensure that we have official evidence of exports made outside of the EU. I believe this is related to the zero-rating of VAT on export shipments. We have checked the VAT Notice 703 and believe that we can comply with the evidence requirements for both direct and indirect shipments - commercial transport invoices and appropriate supplementary evidence. However, we have been advised (from the compliance section of our company based in Germany) that we need to show evidence that goods have been delivered to the customer and not merely shipped. Can you possibly shed some light on this?

Supplying machine tools to manufacture goods for export

10 May 2019

My new client manufactures engineering parts and sometimes has to engineer a machine tool first to enable production to go ahead. They make a charge to the customer for this stage, in addition to the charges they make for the goods they then manufacture and supply. They have entered into a contract with an American company to supply some parts that will be shipped out to the US for the motor industry. We are happy that the client can zero rate the supply of the parts that are exported, but the customer has requested that the machine tool is also zero-rated. I know the customer is a US company, but the tool is remaining in my client’s premises in the UK; what reason could there be to zero-rate it?

Transitional Simplified Procedure and controlled goods

17 April 2019

We import goods from the EU, normally on driver accompanied or unaccompanied trailers. We want to register for the Transitional Simplified Procedure (TSP) but we understand that there are limitations on certain types of goods. I have seen mention of “controlled goods” — do you have any more specific information on what controlled goods are? We import goods that could come under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) controls, eg clothing accessories with feather, leather, etc. Also, will TSP operate at all ports in the UK?

Wooden pallet shortage after EU exit

10 April 2019

We read in the press that there will be a shortage of wooden pallets when the UK leaves the EU. We ship all our goods into the EU on wooden pallets and can’t understand why there might be a shortage. Can you explain please?