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April 4, 2019
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No deal Brexit still a possibility: What should your business do?

If your business imports and/or exports goods with the EU, you may be struggling with the uncertainty around the UK's withdrawal from the EU.

In December 2018, HMRC published a letter for businesses that trade with the EU and steps that should be taken to prepare for no deal. This blog will help you to understand these steps and the actions that you should take.

Firstly, in the event of no deal, you will be responsible for making customs declarations for your UK-EU trade. In order to ensure that you are ready for this, you should:

  1. Register for a UK Economic Operator Registration and Identification (EORI) number. You can do this at gov.uk/hmrc/get-eori.
  2. Register with HMRC’s new Transitional Simplified Procedures (TSP) for customs using your EORI. The aim of this is to make importing easier in the initial period in the case of a no deal. You will be able to transport goods into the UK without making a full customs declaration at the border and postpone the payment of import duties (this may differ for controlled goods). You can register at gov.uk/hmrc/eu-simple-importing.
  3. Decide if you would like to appoint a customs agent who will make customs declarations for you. Many businesses do this and it can make the process much easier. If you would like to do this, it would be a good idea to plan ahead and find out the information that the agent would need from you. If you decide against appointing an agent, you will need to train somebody in your business to make the customs declarations and purchase specialist software which links to HMRC’s customs systems. You would also need to register for the National Export System at gov.uk/guidance/export-declarations-andthe-national-export-system-export-procedures.
  4. Contact the organisation that transports your goods and find out if you will need to provide extra information to them so that they can make the relevant safety and security declarations for your goods. They will also be able to let you know if you will need to submit these declarations yourself.
  5. Check whether your business uses the EU VAT Refund Electronic System, the EU’s VAT number validation service (VIES) or the UK VAT Mini One Stop Shop (MOSS). If so, HMRC advised the following actions in February 2019:
    1. EU VAT Refund Electronic System - Submit your claims before 5pm on the day the UK leaves the UK. After leaving the EU, UK businesses will be able to reclaim VAT from EU countries using the existing processes for non-EU businesses.
    2. EU’s VAT number validation service (VIES) - UK VAT numbers will no longer be part of this service after it leaves the EU. A UK-only VAT number checker will be available on gov.uk, but you will still be able to use the VIES to check EU VAT numbers.
    3. UK VAT Mini One Stop Shop (MOSS) - You should submit your return for supplies made between 1 January 2019 and 29 March 2019 via the UK portal by the normal deadline of 20 April 2019. If you want to continue to use it after the UK leaves the EU, you will need to register for MOSS in an EU Member State by 10 April 2019.

6. Go to gov.uk/hmrc/trade-with-the-eu to find out about what you should do if you are a Non-VAT registered business.

Further HMRC guidance on trading with the EU in the event of no deal can also be found at www.gov.uk/hmrc/trade-with-the-eu.

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