Extension of Transitional Simplified Procedures


Following the creation of Transitional Simplified Procedures ("TSP") to facilitate the speedier movements of imported goods into the UK from the EU and reduce the amount of information required at the frontier, HM Revenue & Customs ("HMRC") have announced an extension to the proposed timescales for submitting the full (supplementary) import declaration and paying any customs duty.

Recently, invitations to register for TSP were sent to companies currently moving goods from the EU to the UK. It was envisaged TSP would last for an initial period of one year should the UK leave the EU with a ‘no deal’ to give companies a chance to prepare themselves for ‘international trade’. TSP will allow goods to cross the frontier without having to lodge a full customs declaration and hence defer paying any import duties at the moment of importation to avoid delays at the UK border.

On 22 March 2019 HMRC announced that it was extending the date when the first supplementary declarations must be submitted, and any import duties paid upon goods already cleared through customs. This date is now 4 October 2019 for any goods imported up to 30 September 2019. (Of course, this is dependent on the UK leaving prior to the revised EU extension deadline of 31 October 2019.)  After this date customs declarations will need to be made on the fourth working day of the following month as per the envisaged TSP system backed by a financial guarantee. It is highly likely that in the event of a ‘no deal Brexit on or after 31 October HMRC will revisit these dates to once again ‘push them on’.

HMRC is also allowing businesses extra time to arrange a financial guarantee to cover any import duties (the introduction of postponed VAT accounting would have already removed the need to pay import VAT at the frontier). Companies will have until 30 September 2019 to arrange such a guarantee/deferment account to meet their ‘deferred’ customs duty obligations.

Lastly, the TSP regime will be rolled out to all ports in the UK not just those dealing with priority ‘Roll on-Roll off’ services to allow greater utilisation of the regime.

Although these initiatives are very welcome to allow businesses to properly complete their preparation and enable, as far as possible, a continuance of frictionless movement, the burden on HMRC’s international trade and compliance officers is obvious; as is the threat to the revenue potentially lost through fraud.

For more information, please cotact Simon Sutcliffe.

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