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Imports: Supplementary decs from 1 Jan 2021 - Pitfalls?

22 October 2020      Andrea Marshall, Tax Specialist

As you may be aware, rather than completing an import declaration when goods enter the UK, you have the option from 1 January 2021 to 30 June 2021, to complete a supplementary import declaration after the date of entry. You have until 30 June 2021 to complete this declaration. From 1 July 2021, an import declaration will need to be completed as goods arrive in the UK.  There reason for this option is to prevent a delay at port and airports as goods are brought into the UK.

HMRC have issued guidance on: "Making an import declaration in your records without authorisation” from 1 January 2021" and "Prepare to make supplementary declarations from 1 January 2021" .

The first guide is the most important for universities, as it sets out the information that will needed in order to make a supplementary direction. The second document is less relevant to the sector as it sets how you apply to do this without using an agent to do the declaration for you. As the majority of universities use shipping agents, this is unlikely to apply widely.

The information you will need is:

  • the customs procedure code
  • a unique consignment reference – this could be invoice number, stock record number or job number
  • purchase number (and if available, the sales invoice numbers)
  • the date and time of entry in records – creating the tax point, which is used for working out VAT payments later
  • a written description of the goods – so they are easy to identify
  • the commodity code based on the description of the goods
  • customs value
  • quantity of goods – for example, number of packages and items, net mass

Please remember that if this facility is used, it is JUST for the payment of import duty.  If you go down the supplementary declaration route, you will have to use postponed accounting (i.e. self-charge VAT) on the VAT return covering the date that the goods enter UK. You will also need to complete an Intrastat return if you are over the limit and import the goods from the EU.

So for example, 

  • Goods enter on 1 March 2021
  • Intrastat declaration for March 2021 may be required
  • VAT will have to be accounted for on the April 2021 VAT return 
  • Supplementary declaration completed on, for example,  24 May 2021
  • Import Duty paid shortly after this (depending on the length of time that your agent allows)

Timing wise this could be problematic, as import VAT is calculated on customs value + import duty.  As you can see from the above example, you will not have this figure at the time you submit the VAT return, so you may need to initially estimate the import VAT due and then correct it on the July 2021 VAT return.



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