EU VAT webinar slides

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Get in touch! DIT France Team: CommercialEnquiries.Paris@fco.gov.uk; Irini.Hajiroussou@fcdo.gov.uk; Adrienne.ScottCox@fcdo.gov.uk

Stay on top of UK-France trade updates: 📧📧 Sign up to our EU Exit News Flashes DIT’s New Export Support Service: • •

https://www.gov.uk/ask-export-support-team 0300 303 8955

Adrienne Scott-Cox, DIT France, British Embassy Paris


Breakdown of customs brokerage services


Who Are Unsworth? Unsworth was established in 1974 and has demonstrated 48 years of continued growth as a global freight and supply chain specialist. Financially sound with an annual group revenue of over £54m, growing year-on-year. Unsworth are the largest independently owned consolidator in the UK, running over 30 groupage containers each week from China and other ports.


Preparation We support with the preparation and submission of necessary documents to clear customs and can help arrange the correct payment of import duties and VAT, as required. Pathway simplifies document control, and adds security.


Communication Completely transparent notifications and updates, when you want them, as they happen. We work diligently with local authorities like HMRC and Port Health on behalf of our clients, taking all of the complications and hassle out of the process for them.


Classification We will maintain an exhaustive product database securely for complete compliance.

check classification and valuation of every declaration to ensure the right commodity codes are being used and we will advise on necessary licenses for the import of certain goods.

We


Reporting Enterprise level reporting tools, made available to all. From SME’s through to Multi-National Businesses. Quickly identify overspend and preferential gaps with cutting edge, transparent reporting.


Visibility Industry leading tactical and strategic declaration visibility. Whether our clients are checking status of individual declarations, weekly or monthly snapshots, the powerful real-time view of Pathway decreases friction, and improves collaboration across all asset owners.


Preparation Compliance Communication Classification Reporting Visibility During periods of changing regulations, compliance breaches are the single biggest risks to a business’ bottom line. Our experienced operations team are supported by industryleading technology, reduce friction, improve compliance to regulations and increase collaboration between asset owners.


Haulier Portal Since January 2022 the Goods Vehicle Management System is live! Our industry first haulier portal helps drivers and transport planners access critical information in realtime, reducing delays at the border.


Short Straits User Forum This is setup and run by UK shippers to streamline the Calais port process and get better engagement from all at the Port of Calais. To find out more, google ‘Port User Forum’ or go to www.portuserforum.com. Scan the QR code below to sign up.

NEW EVENT 5th April Supported by the French regional government, Port of Boulogne Calais, Customs, SIVEP and regional authorities we are hosting another event focusing on:

• Full UK Export via Dover process to French Import/ Customs/SIVEP with Q&A with authorities •

IBF Sevington

• UK Import process walkthrough and tour by Port of Calais •

Details

(SSUF)

of the Short Straits Users Forum


CONTRACT LOGISTICS

INLAND TRANSPORT

CUSTOMS BROKERAGE OVERSEAS TRANSPORT


Customs & Compliance solutions

 More than 80 professionals

Our customs brokers coordinated in France, Portugal, Belgium, Netherland, Ireland, Portugal and Switzerland

ecuring services / Tariff classifications of your declarations identified and secured by our experts (Species, Origin, Value).

 AEO-C & AEO-F  Digitized customs procedures  Experienced and trained brokers

gent services / Our customs brokers carry out all your declarations and formalities on your behalf.

 EU/UK Expertise with Clément ALLOUL  A dedicated team of expert brokers for

BREXIT UK customs clearance operations

luidizing services / Bonded warehousing and transit, Inward & Outward processing relief. Let’s manage time and space for your customs clearance operations

mpowerment services / Training, AEO Consulting, new regulations monitoring, our experts assist your team for greater autonomy on your customs clearance issues.

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BBL’s BREXIT Team  10 experienced customs brokers 

dedicated for BREXIT clearances ONLY

 Specialization in Veterinary/Phytosanitary processes 

3 staffs dedicated

 All kind of goods cleared 

Food and Beverages, Wine and Spirits, POAO, Animal Feed and General Cargo

 Covering full week assistance 

from Monday to Sunday

 Automatized process 

Clearance of 200 commodity codes in a short time (- 20 minutes)

 Single Brokerage partnership  Tuesday, 15 February 2022

Attractive rates

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Import to the EU Ensure to well prepare your shipment

 Analyze your product’s origin 

British origin of goods offer 0% duties rate

 Determine the commodity code  10 digits are required in the EU

 Obtain an EU EORI number  To proceed via the DDP solution and act as the importer

of records

 Commercial invoice producing  Including all relevant information

 Choose an experienced and professionnal customs

broker Tuesday, 15 February 2022

16


Smart Border Automatic clearing process

17 Tuesday, 15 February 2022


Clearance process Automatic clearing process Status which means truck is still in the UK  Clearance request send

by the British exporter Commercial Invoice  Packing list Routing (e.g: Dover – Calais) 

 Import clearance is

raised by BBL

 Barcode DAU, status: ANTICIPATE (until 30 days before departure)

 Export clearance is

raised by Unsworth 

EAD

18 Tuesday, 15 February 2022


Clearance process Automatic clearing process

 Paperworks are given to the driver  Both barcode + EAD must be scanned at Dover / Folkstone before boarding

 Driver must check his truck status

during the crossing 

On screens onboard

19 Tuesday, 15 February 2022


Smart Border Automatic clearing process

 GREEN LINE = driver can GO  

Goods are cleared and into free circulation Driver can immediately leave the terminal and deliver the goods

 ORANGE LINE = driver must STOP  

A customs check is required A SIVEP (sanitary/veterinary/phytosanitary) check is required clearance needs to be validated manually 20

Tuesday, 15 February 2022


INTRODUCTION

Some key facts about RM Boulanger

1981

30

315.000€

Founded

ADDRESS Rue du Vertuquet 17A, Neuville-en-Ferrain, France

Share capital

Employees

PHONE +33 (0)3 20 25 70 70

900

Customers established in 45 countries

E-MAIL contact@rmboulanger.com

2.8bn Transactions reported to the National Tax Authorities

WEBSITE www.rmboulanger.com


WHAT WE DO • VAT registration & compliance across all the EU member states, • Overall VAT consultancy services, • Dedicated Brexit services (both for EU and UK companies), • Acting as the ‘responsible person’/economic operator in the EU for CE-marked products.

IN A NUTSHELL: assisting companies to trade within the EU as if Brexit NEVER happened!


MEET ALLAN

We are delighted to introduce you to our UK based expert : •

Allan Vincent - UK Sales Manager based in the UK

Joined RM Boulanger in December 2021

Advising UK based companies on their VAT liabilities in the EU

Providing clients with short and long term solutions regarding the new VAT rules

DON’T HESITATE TO GET IN TOUCH WITH ALLAN : a.vincent@rmboulanger.com

+44 (0) 7850 632194


Main bottlenecks today arising from Brexit

1

2

3

4

Complexity of Customs processes

Veterinary and Sanitary inspections and certification

Huge pressure on supply chain and delivery times

Administrative burden

5

2 4

Not enough awareness regarding fiscal liabilities. VAT is an issue that needs to be managed carefully.

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


The reality from a fiscal point of view since January, 1st 2021

B2B transactions are no longer EU- harmonized and are now treated as export and import transactions between the EU and the UK

Import customs duties are to be paid in the EU (unless products qualify as of UK origin)

Products imported in the EU trigger VAT import

Most of EU clients require to be supplied on a DDP basis.

RMB can help you map your flows and determine how to ship DDP to the EU as if Brexit did not happen!

2 5

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


BEWARE OF THE NEW VAT RULES

Importers / Sellers in France (B to B & B to C)

French VAT number needed

IMPORT VAT DEFERMENT / « AUTOLIQUIDATION» WILL BECOME MANDATORY AS PER JANUARY, 1st 2022. A French VAT registration is therefore required for all companies importing goods into France from January, 1st 2022! 2 6

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


BEWARE OF THE NEW VAT RULES FROM JANUARY, 1st 2022

AS A RESULT:

2 7

The VAT on import is no longer payable to your French customs broker,

You cannot sell DDP to French clients if your company does not have a valid French VAT number,

VAT refund reclaims through the 13th directive are no longer possible for import VAT.

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


BEWARE OF THE NEW VAT RULES FROM JANUARY, 1st 2022

Downside of these measures: VAT registration in France can take up to 3 months. A BLESSING IN DISGUISE: •

No IMPORT VAT to be prefinanced ever again,

No longer stuck in time-consuming procedures to get the VAT on import refunded,

One VAT number that can be used to deliver DDP to both French and other EU clients,

 It will be worth waiting 2 or 3 months to be VAT registered!

2 8

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


BEWARE OF THE NEW VAT RULES FROM JANUARY, 1st 2022

What can RMB do for you so that your imports in the EU are not blocked while your VAT number is being processed? •

Share our global VAT number and use REGIME 4200, 

2 9

This solution is only applicable to DDP sales in the EU but NOT in France.

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


HOW TO KEEP ON SELLING DDP AFTER JANUARY 1st 2022? •

3 0

Obtain an EU EORI NUMBER. This is a customs ID number, enabling you to perform imports in any EU country on your own name. Easy to get, we can take care of it in usually less than 24 hours.

Appoint RMB as your Tax Agent and register for VAT  Enabling you to use postponed VAT accounting,

Appoint a Customs Broker in the UK to fulfill the export formalities,

Appoint a Customs Broker in France to clear your goods and fulfill the import formalities on behalf of your name.

France remains an attractive import country: •

Mutual tax reciprocity between France and the UK,

No requirement to set up a bank guarantee with the French tax authorities,

Lower VAT compliance costs.

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


CASES

CASE 1: Your company sells to French businesses only OUR SOLUTION Register for VAT in France and benefit from a full import VAT deferment on all imports.

BENEFITS

• •

Import VAT is exempted on all goods, Your company has its own French VAT number that can be potentially used to sell to other EU member states on a later stage (business expansion, etc.).

PROCESS

● Appoint a customs broker in France, ● Appoint RMB as your tax agent in France, ● Mention your own French VAT numbers on your invoices, ● RMB will report these transactions to the French Tax Authorities for VAT purposes.

Note that having a French VAT number will allow you to sell goods in other EU member states as well. 3 1

CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


CASES

CASE 2: Your company sells BOTH to French and EU-based clients OUR SOLUTION Register for VAT in France with RMB AND use limited tax representation (regime 4200) as a temporary solution for goods being sold to EU-based clients, until receiving your own number. Once registered for VAT in France, benefit from a full import VAT deferment on all imports, regardless of the destination of goods.

BENEFITS

• •

3 2

PROCESS

● Appoint a customs broker in France, ● Appoint RMB as your tax agent in France, ● Mention your own French VAT numbers on your invoices, ● RMB will report these transactions to the French

Tax Authorities for VAT and INTRASTAT purposes.

Import VAT is exempted on all goods, whether they are shipped to EU customers or sold to French clients, Your company has its own French VAT number. CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


CASE 2

Your company sells to all EU businesses, both French and other EU alike UK

LONG TERM SOLUTION VAT REGISTRATION IN FRANCE

FRANCE

(COUNTRY OF EXPORT)

(COUNTRY OF IMPORT) Imports of goods coming from the UK

Exports of goods departing from the UK

Local sales to non VAT registered consumers

Import VAT deferment UK companies will need to request a new EORI number valid in the EU

French VAT number

EUROPEAN UNION

HOW TO SELL DDP AND AVOID THE USE OF T1’S IN THE EU

Exports

IntraEC deliveries French VAT number

Companies established within the EU

33

Non VAT registered consumers

OUTSIDE THE EU Companies non established within the EU

French VAT number

French VAT number


CASES

CASE 3: Your company sells to EU businesses (except French) using France as the sole point of entry in the EU THE LIMITED TAX REPRESENTATION (REGIME 4200)

PROCESS

● Can be used immediately,

● Appoint a customs broker in France,

● No VAT to pay upfront at the time of import in France,

● Goods are customs cleared in France in your name,

● No VAT registration required in France,

● Goods are immediately transported to your EU customers,

● Your goods are shipped from the UK to all EU countries on a

● Your company mentions RMB's Global VAT number on invoices,

DDP basis,

● Your clients are not involved in the customs process in their countries.

OR REGISTER FOR VAT IN FRANCE FOR MORE TAX STABILITY 3 4

● RMB will report these transactions to the French Tax Authorities for VAT and INTRASTAT purposes.

THIS METHOD IS NOT APPLICABLE TO SALES IN FRANCE CONQUER EUROPE WE’LL HANDLE THE PAPERWORK


CASE 3

Your company sells to EU businesses (except French), using France as the sole point of entry in the EU COUNTRY OF DESTINATION

COUNTRY OF IMPORT

EoR = UK supplier

IoR = UK supplier

R4200 : Limited fiscal representation

Invoic e

VAT

UK companies will need to request a new EORI number valid in the EU

THE 4200 CUSTOMS REGIME ISN’T APPLICABLE FOR SALES IN FRANCE (other solutions for this) 35

EUROPEAN UNION

FRANCE

UK

COUNTRY OF EXPORT

HOW TO SELL DDP AND AVOID THE USE OF T1’S IN THE EU

IntraEC deliveries

Invoic e

Companies established within the EU

VAT

Box 2 : UK supplier+ N° EORI UK Box 8 : UK supplier + N° EORI UE Box 17 : Country of destination

Box 37 : 4200 customs regime Box 44 : Y041 (UE VAT number of the EU client at destination) + Y042 (Limited tax agent VAT number in France)


CASE 4

Your company imports in the UK France / EU

UNITED KINGDOM

(COUTRY OF EXPORT)

(COUNTRY OF IMPORT)

Exports of goods departing from the EU

Imports of goods coming from the EU

UK client

UK VAT number Import VAT deferment

Local sale, local UK VAT to be applied Invoice

VAT

1. The EU company needs a new EORI number in the UK, 2. The import VAT paid (before receiving the VAT number) will be claimed back through the 1st VAT return. 3. When VAT number is received, postponed VAT accounting can be used to defer import VAT 36

HOW TO SELL DDP AND AVOID THE USE OF T1’S IN THE EU


Q&A SESSION

This presentation was produced by RM BOULANGER in consideration of the texts and data available on the date of its presentation. The information it contains as well as that communicated orally cannot be considered as advice or consultation. RM BOULANGER is not responsible for the accuracy or completeness of this content and is not responsible for any errors or omissions.


CONQUER EUROPE WE'LL HANDLE THE PAPERWORK

THANK YOU FOR YOUR ATTENTION ! We remain at your disposal for any questions or additional information.

This presentation was produced by RM BOULANGER in consideration of the texts and data available on the date of its presentation. The information it contains as well as that communicated orally cannot be considered as advice or consultation. RM BOULANGER is not responsible for the accuracy or completeness of this content and is not responsible for any errors or omissions.


MICHAEL BOULANGER

ALLAN VINCENT

ARTUR SARKISIAN

Tel. +33 3 20 25 70 70 m.boulanger@rmboulanger.com www.rmboulanger.com

Tel. +44 7850 632194 a.vincent@rmboulanger.com www.rmboulanger.com

Tel. +33 3 20 25 70 84 a.sarkisian@rmboulanger.com www.rmboulanger.com

CEO - RMB

SALES MANAGER UK -RMB

OPERATIONAL MANAGER - RMB

ADRIENNE SCOTT-COX

CLÉMENT ALLOUL

CHARLES HOGG

Tel. +33 1 44 51 34 35 Adrienne.ScottCox@fcdo.gov.uk www.great.gov.uk/markets/france

Tel. +33 7 50 64 32 70 c.alloul@groupe-bbl.com www.groupe-bbl.com

Tel. +44 20 8539 8899 ch@unsworth.com www.unsworth.uk

MARKET ACCESS OFFICER FRANCE - DIT

BREXIT MANAGER - BBL GROUPE

COMMERCIAL DIRECTOR - UNSWORTH


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