Appropriate Customs Processes and Systems

New Guidance from HMRC

 

Many companies struggle in coming up for a vision of what appropriate customs processed and systems should look like.

 

Given customs duty compliance is subject to audit based control, these processes and systems will be under scrutiny by the tax authorities at some point. Useful guidance on this matter was issued as part of the updated Senior Accounting Officer (SAO) Guidance Manual to HMRC staff in April 2012.

 

Meeting these requirements is a legal obligation for large companies (turn over £200m plus) and failure can lead to personal liability for the nominated SAO. Adopting these requirements will help all businesses control compliance risks and utilise appropriate elections to ensure duty is not overpaid.

 

The guidance provides companies should:

1. Ensure compliance with legal requirements
2. Carrying out periodical checks of systems, controls, process flows and transactions
3. Supporting the introduction of new systems or processes or changes to them through appropriate planning, risk assessment, implementation and evaluation
4. Maintenance and retention of required records
5. Appropriate staff training
6. Checking third parties to whom responsibilities are delegated are appropriately trained, have necessary guidance, qualifications, knowledge and experience to carry out their function
7. Gather all relevant facts and advice to allow the company to make customs sensitive judgements (e.g. using duty relief regimes, valuation planning etc.)  

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