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i2i EU Exit No-Deal Position Statement - Updated

Brexit – No Deal Preparation Update

 

As the EU Exit date of March 29th draws ever closer, and with Parliament still undecided on whether or not we should leave with a deal, we thought it important to bring you, our customers, up to date with the latest information that you need should the UK leave the EU without a deal.

A lot of this information will already have been provided to you by HMRC, but we are including it here in one place for your convenience.

We also feel that it is important to reassure you that all of our core products (e-z GTA, e-z Cert, and e-z Consign) have been updated to handle a ‘No Deal’ scenario, so if needed then we will enable this functionality immediately upon our ‘No-Deal Exit’ from the EU.
 

New and Additional Information required for a No-Deal EU Exit Scenario

In the event of a No-Deal EU Exit, several new codes and changes to existing codes will be introduced to our software when making declarations to HMRC.  You need to be aware of these when completing your customs and excise entries:

 

NES & Imports Module

  • Mode of Transport ID 6 (RoRo) added to the mode of transport stored data.
  • New location codes added to the port code stored data for:
    • Dover/Eurotunnel - GBDEU
    • Eurotunnel - GBEUT
    • Killingholme - GBKIL
    • Purfleet - GBPUF

      New Additional information statements can be entered into box44 in the following format:

    • AI=trailerID/registration-ROVRN; (to supply the transport id details)
    • AI=RODEP; (to advise you will also be supplying the departure details)

System Changes

  • Country code stored data will be updated to mark EU27 counties as third countries

EMCS

  • Destination Type Codes - The list will be reduced to 'Tax Warehouse' & 'Export'
  • Guarantor Type Codes - Option 5 (no guarantee) will be removed
  • Trader Type - Only 'UK Record' allowed
  • Transport Mode Codes - Type 7 (fixed installation) will be removed
  • Splitting - This functionality will be removed
  • Degree Plato - Field removed.
  • LTS validation will also be updated to the D1ND version to support validation of the above changes

 

EORI Registration


Since late last year, HMRC have been advising the following:

If the UK leaves the EU without a deal, an EORI number will be essential for any business trading with the EU after 11pm on 29 March 2019. Applying for an EORI number is the first step for businesses, who currently only trade with EU countries, to start engaging with the customs system.
Businesses do not need a new EORI number if they are trading with countries outside the EU and therefore already have one (it will start with GB [and be followed by 12 numbers]).

i2i are aware that within the past few days, HMRC have announced a new online method of registering for an EORI for those that have not already completed this step:
The new digital system means most traders will get an EORI number within ten minutes if their application is successful. It may take longer if their application is not straightforward.

How to get an EORI number

Traders will need:

  • their Government Gateway user ID and password. If they don’t have a Government Gateway account, they’ll need to create one
  • other information about their business, such as their UK tax identifiers (VAT number and Unique Taxpayer Reference (UTR) if held, or their National Insurance number if they’re an individual or sole trader).  


Traders who are applying for an EORI but do not meet the key criteria, for example, are not established in the UK, will be directed to a different form during the process.
If they are unsure if they already have an EORI number, they can contact the EORI team on 0300 322 7067 or by using the online form.

Making customs declarations after getting an EORI number
Getting an EORI number will not immediately enable traders to make customs declarations. They should speak to their agent or software provider about additional steps they need to take. They can also find more information on making customs declarations if the UK leaves the EU without a deal at www.gov.uk/hmrc/declare-goods.

If you are not already using NES functionality to declare your own export entries to HMRC, and feel that you would benefit from this functionality in e-z GTA or e-z Consign, then please do not hesitate to get in touch with us to discuss the requirement further.
 

Subscribe to HMRC Information regarding EU Exit
In February HMRC wrote to businesses giving them an update on the Brexit situation, and recommending that individuals should register for HMRC emails via a subscription service that they provide.

We wish to reiterate this advice, and would suggest that you sign up at www.gov.uk/hmrc/business-support, and choose the link for ‘Business Help and Education emails’ and after registration choose the subscription for ‘EU Exit’.

 

Importing using Transitional Simplified Procedures (TSP)

HMRC have advised that, if needed, UK traders should find out if they can register to use Transitional Simplified Procedures to import goods from the EU into the UK in the event of a No-Deal EU Exit.

TSP will make importing from the EU easier in the aftermath of a No-Deal EU Exit, and for 15 months after the departure date businesses will be able to import from the EU without needing to make a full customs declaration at the border.

Further details can be found here: https://www.gov.uk/guidance/register-for-simplified-import-procedures-if-the-uk-leaves-the-eu-without-a-deal


Common Transit Convention (CTC)

 
CTC allows goods to move between the UK, EU countries and other CTC countries under “duty suspension”, meaning that duty does not need to be paid until goods arrive at their final destination.
The benefits to businesses include cash flow benefits and keeping movement of goods flowing quickly.  Under CTC, movements must:

  • Start from an ‘office of departure’, (a government office), or at your own or an agent’s premises if you or they are an authorised consignor.
  • Pass through an ‘office of transit’ to record the entry into the new country when the goods cross into a new customs territory (ie. the first entry in to the UK from a CTC country). 
  • End at an ‘office of destination’, (a government office), or at your own or an agent’s premises, if you or they are an authorised consignee. You must then enter the goods into another customs procedure, or into free circulation.

 
Offices of Destination and Departure are likely to be extremely busy in the event of a No Deal exit from the EU. You should consider finding an authorised consignor/consignee or applying to become one.

More information on CTC can be found here.

Intrastat


It is the understanding of i2i that the requirement to report upon Intrastat will cease upon a No-Deal EU Exit.  As such you should submit further Intrastat reports pertaining to trade after the EU Exit date only at your own discretion.

Further reading and other resources:

https://www.gov.uk/government/publications/partnership-pack-preparing-for-a-no-deal-eu-exit

https://www.gov.uk/government/publications/hmrc-impact-assessment-for-the-movement-of-goods-if-the-uk-leaves-the-eu-without-a-deal/hmrc-impact-assessment-for-the-movement-of-goods-if-the-uk-leaves-the-eu-without-a-deal

We hope you have found this post useful, and please do not hesitate to contact us should you wish to discuss how a No-Deal Scenario will affect your e-z software in more detail.

i2i Infinity Ltd