Post Brexit Impacts from 1 January 2021
Indirect Tax Matters August 2020
Have you reviewed your supply chain – could you/should you secure a comparable non-UK duty-free supplier/buyer from within EU? Remember, many raw materials, products and finished goods sourced from/delivered to UK will bear import duty (tariffs) post 31 December 2020 (excl. orders posted pre 31 December 2020).
- All imports and exports (to/from UK) will require formal declarations and documentation relating to each transaction.
- All transactions, either import or export, will likely trigger tariffs (duties) and VAT upon arrival into respective country.
- Have you considered/arranged who will prepare import declarations into Ireland/EU?
Responsibility for meeting customs obligations at import falls on the importer of record.
International commercial terms (Incoterms/FOB, ex Works, etc.) establish the obligations of seller and buyer, i.e., which party carries risk, who pays carriage, where/when title passes and payment of import charges such as duty and VAT.
The UK has introduced its own tariff, the UK Global Tariff. Currently, it’s unclear if there will be a trade deal negotiated between now and 31 and December 2020, accordingly, exports from Ireland into the UK could attract positive rates of import duty.
Customs Regimes and Simplifications
Customs authorisations such as Inward Processing and Customs Warehousing, Transport, etc., could be used to simplify arrangements and mitigate tariffs. Also, New Computerised Transit System (NCTS) is an imperative for Irish traffic, W to E / E to W, using the UK land-bridge to/from mainland EU.
The main change is that purchases of goods from and sales to the UK will become imports and exports respectively. Businesses should review the VAT treatment of all their transactions with the UK to ensure that they are treated correctly from a VAT perspective.
Systems and data
Customs and VAT systems, processes and data need to be reviewed and updates scheduled to allow sufficient lead time for implementation.
Northern Ireland (NI)
A new unique trading position has been agreed for NI which remains within both the EU and UK territories. Broad alignment to EU rules on goods but not services in NI, including customs (where the EU Union Customs Code applies) and VAT (EU VAT law for goods). Detailed terms remain to be confirmed during this transition period.
We are the only major professional services firm that offers end-to-end trade compliance solutions. Our Global Trade Bureau is truly unique in making the declarations that will allow your goods to move post Brexit UK-Ireland/EU or Ireland/EU–UK. See here for more details.