Managing ‘at risk’ goods post Brexit and postponing duty payments for ‘at risk’ goods

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From 1 January, when bringing goods into Northern Ireland from the UK or from countries outside of the EU, you may need to pay any tariffs due. Depending on where you are bringing the goods from and whether they are ‘at risk’ of onward movement to the EU, will dictate whether you have to pay duty, and how much that duty is.

The Government has reached an agreement in principle with the EU as to when goods moving into Northern Ireland are considered not ‘at risk’ of onward movement into the EU under the terms of the Protocol. Click here to find out further details on this.

As part of the agreement, the UK Government has launched the UK Trader Scheme, allowing approved businesses to declare that the goods they bring into Northern Ireland are not ‘at risk’ of onward movement to the EU such that the EU duty will not be due on these goods.

The Government are urging businesses moving goods from UK to NI to consider whether to apply for the UK Trader Scheme. In order to declare goods not ‘at risk’ from 1 January 2021, traders must have applied for UK Trader Scheme authorisation by 31 December 2020, this has been extended from the 23rd November.

The scheme will be focused on goods being sold to, or provided for final use by, end consumers located in Northern Ireland or, for internal UK trade, elsewhere in Great Britain.

You can find further information on ‘at risk’ and how to apply for the UK Trader Scheme on the gov.uk website.

Postponing duty payments if your goods are ‘at risk’

If you move goods between the UK and Northern Ireland after 1 January 2021 that are classed as ‘at risk’, you may need to pay duties if you are unable to claim a waiver. This duty will need to be paid after your goods have been delivered, either when requested by TSS or through your own Duty Deferment Account (DDA) on the 15th of the following month.

There is an option to postpone when you pay this duty. In order to do this you should apply for a DDA via the gov.uk website. After doing so, you can then provide your Duty Authorisation Number (DAN) to TSS to pay for deferred duties via the portal. Details will provided in January about how the government will use your DDA to pay duty that is due on the declarations which they raise for you.

Once you’ve set up your DDA, you will need to set up a direct debit instruction with your bank or building society. The government has this week updated the guidance on how to set up this direct debit, which is explained here.

This updated advice states that if are using both the Customs Declaration Service (CDS) and the Customs Handling of Import and Export Freight (CHIEF) for declarations, you will need to set up separate direct debit instructions for each of these systems. However, if using both CDS and CHIEF, you will not be charged twice for the same duty you are liable for.

For more guidance and information contact our friendly expert Ruth Corkin on ruth.corkin@hhllp.co.uk or 03300243200 and she’ll be happy to help.

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Ruth Corkin

Ruth has been involved with VAT for over 30 years. She started her VAT career as a Customs and Excise Officer in Essex and then moved into consultancy with a variety of well-known accountancy firms. She is well known in the VAT world and is the proud author of many articles and technical works.

Contact Ruth at ruth.corkin@hhllp.co.uk or on 01908 713 860