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The new EU-wide Import One Stop Shop (IOSS) will go live from 1 July 2021.

From that date the current VAT exemption for goods in small consignments of a value of up to €22 is abolished and all goods imported into the EU will be subject to VAT.

The IOSS will allow suppliers making distance sale of goods imported from third countries to final consumers in the EU (e.g. online retailers) to declare and pay the VAT due on those goods by submission of a monthly return via the IOSS in the Member State where they have registered for the scheme.

Continue reading about the new EU VAT changes

Postponed Accounting for VAT on imports is available from 1st January 2021. It provides a major cash-flow benefit for traders who import goods from all non-EU countries into Ireland.

Postponed Accounting enables you to self-account for import VAT on your VAT returns rather than having to pay import VAT upfront. It also allows you to reclaim import VAT at the same time as it is declared on a VAT return, subject to normal rules on deductibility.

There are two steps to ensure you can apply postponed accounting to your imports:

Step One – Make sure your business is entitled to use Postponed Accounting

  • Traders who were registered for both VAT and Customs & Excise (C&E) with Irish Revenue at 11:00pm on 31 December 2020 have been given automatic entitlement to Postponed Accounting.
  • VAT registered traders who were not registered for C&E at 11:00pm on 31 December 2020 and who wish to import goods into Ireland must register for C&E (i.e. must obtain an Irish EORI number). Once registered for C&E, they will be given automatic entitlement to Postponed Accounting.
  • After 11:00 pm on 31 December 2020 all new intra-EU VAT applicants must get their Irish VAT number issued and then must register for C&E. When both the VAT and C&E registrations have been approved the applicant must request access to Postponed Accounting from Revenue.
  • After 11:00 pm on 31 December 2020 domestic-only VAT applicants who acquire goods from countries outside of the EU VAT area must apply to Revenue for Postponed Accounting and submit certain supporting documentation. Domestic-only VAT applicants will receive confirmation from Revenue when their Postponed Accounting application has been granted. Applicants will not have access to the Postponed Accounting facility prior to this confirmation.

Step Two – Make sure the electronic customs import declaration is completed correctly

  • The appropriate fields must be completed on the customs import declaration or you may be required to pay import VAT upfront.
  • Revenue have issued guidance on exactly what needs to be inputted on the AIS and AEP systems.
  • If you do not complete the customs import declaration yourself, you should tell your supplier or customs agent that you wish to avail of postponed accounting for import VAT and ensure that the customs import declaration indicates this to Revenue.

For further assistance, please contact Siobhán O’Hea, Partner in our Tax Services Department.

Do you trade with the United Kingdom, or transport goods to/from Europe via the UK? Then you will need to consider the impact of Brexit on your organisation and put in place an action plan to ensure you are best prepared for when the transition period ends on 31st December 2020.

Supply Chain
Review your supply chain. Map the movement of goods into and out of the UK and goods going to and from Europe via the UK, to understand the potential for disruption caused by Brexit (possible delays, clearance requirements, additional checks on goods etc.) Consider actions you can take to prevent this disruption.

Customs Clearance
If you intend to import/export goods to and from the UK, you will need to be registered with Customs. Customs declarations will be required in order to move the goods through the border.

  • Ensure you have an Irish Customs registration number- ‘EORI number’ beginning with IE
  • You will also need a UK EORI number beginning with GB
  • Engage with a customs clearance agent/broker to lodge Customs declarations on your behalf.

Customs Duty
Customs Duty will apply to the import of many goods from the UK into Ireland and vice versa. It is non recoverable and is an additional cost to the business.

  • Ensure you correctly assign the correct commodity codes to the goods imported/exported. The codes will be needed in customs declarations and will determine the amount of duty to be paid.
  • Consult with your agent/broker to see if any reliefs are available.
  • Establish whether you need to obtain a ‘Deferred Payment Account’, this will allow you to import goods into Ireland from the UK and defer the payment of Customs Duties and Import VAT to the month following import.

Vat on Importation
The Irish Revenue passed a bill allowing for the “Postponed Accounting” for VAT on importation where businesses would no longer pay VAT at importation. You can instead account for VAT through the normal monthly VAT return resulting in a significant cash flow saving.  However, they will introduce qualifying criteria for this provision over time. If you do not qualify, VAT (currently 21% for ROI) will apply to the import of many goods from the UK into Ireland and will be payable at the time of import of the goods into Ireland.

Product Certification
The area of product certification will change post-Brexit. UK notified bodies will lose their status as EU notified bodies and will not have any legal status in the EU. This means they cannot provide EU certification. If you rely on UK notified body, you must source an alternative notified body in the EU.

  • More detailed information is available at www.nsai.ie/brexit

Exchange Rates
Currency/exchange rate exposures are a risk for businesses trading in foreign currency. You can take steps to help reduce your exposure.

  • Consider Dual Invoicing
  • Currency Hedging/Forward contracts

ERP Systems
Companies should assess the changes required to be made to their ERP/Finance systems and the time/cost that it will take to implement these changes.

For further assistance, please contact Edward Murphy | Partner | Head of Tax services.

For further information you can visit the below websites or call your local enterprise office.

www.gov.ie/brexit

www.revenue.ie/brexit

www.localenterprise.ie/brexit

www.prepareforbrexit.com