How to survive a Customs Import/ Export Audit

International Trade:

John Griffiths ITDLO

Why do we audit importers/exporters

HMRC are responsible for assuring that

importers/exporters

� comply with EU legislation

� provide accurate UK statistics

Therefore our aim is to improve compliance (‘Right Tax,

Right Time’) in the legitimate trade.

To help you get it right !

Ground rules: your responsibilities

Satisfactory record-keeping systems are required.

Records to be kept for at least 4 years for customs duty

(3 + current).6 Years for Import VAT ,

Customs must be allowed access to records and be

satisfied that all requirements of schemes are met.

Your premises will be visited for audit purposes.

The Law

Finance Act 1994

Customs and Excise Management Act

Customs Traders (Accounts and Records) Regulations

European Union Legislation- Union

Customs Code – Reg 952/2013

Delegated Act –Reg 2015/2446

Implementing Act –Reg 2015/2447

Preparing for an Import/Export Audit

Preparing for an Imports/Export Audit

Obtain copies of Export C88’s/SAD/Entries from your

freight forwarder.

Customs may look at information from sales contract

through to import/export and receiving payment for the

goods.

Any commercial and official (NES) evidence required to

support zero-rating of goods.

IPR, OPR, Temp. Exports all need correct evidence of

Export.

Import Audit

• Customs may want to see

• Sales Contracts /emails

• Commercial invoice with incoterms –eg Ex works , FOB,

CIF ,

• Bill of lading / Airwaybill ,packing lists

• Freight forwarders invoice –evidence of haulage paid

• C88/ SAD .

• Payment terms –ledgers Bank payments .

• Evidence of valuation Price paid or payable if method 1 .

Export Audit

Customs will check declared values and licensable goods

Export Preference Declarations

Evidence of Export -

Arrival & Departure Messages

Direct Exports

• For goods leaving the UK directly for a non-EU destination

a departure message must be sent to CHIEF.

Departure Message may be sent by:

• The CSP at inventory linked air/port (automated process)

• Authorised Third Party ‘Loader’

Indirect Exports

• Goods exported via an EU Member State do not require a departure message from the UK – however

• Export Accompanying Document (replaced travelling copy 3 of the SAD wef 1/7/09)) is required to travel with the goods for presentation at the office of exit from the EU

Arrival & Departure Messages

CDS –Customs Declaration Service

• More Information will be required from Importers and

Exporters to enable the declarant (usually the Freight

Forwarder or Third Party Service provider) to complete

Import / Export Declarations on your behalf

• E.g. Parties involved in a declaration- Seller details

required if Seller is different to Exporter . Buyer details

required if Buyer is different to importer .

• More information re Valuation needed if goods are going

entered to free circulation and Valuation method 1 is

used .

During the Audit

Make available all relevant documentation you feel would

be useful/supports the audit trail.

Provide any documents that we may have asked for.

Ensure you have allocated enough time for the Audit –

we may need to ask you questions!

Be as helpful as possible, the more you help us the

quicker and easier it is for you.

Cup of tea or coffee always helpsG.

After the audit

Provide any extra information that the Audit officer may

have asked for as soon as possible.

Submit any claims for refunds.

Pay any requests for underpayment –C18’s that you may

have been issued.

Penalties

Review and Appeal.

Compliance

Our aim is to improve compliance (‘Right Tax, Right

Time’) in the legitimate trade.

The more you get things right the less likely we will visit

you, the more you get it wrong the more often you will be

visited.

Do you need more help?

HMRC Contact Centres – initial contact for basic enquiries: Tel:0300 200 3700.

HM Revenue & Customs websites:

www. gov.uk

Tariff Classification Service: classification.enquiries@hmrc.gsi.gov.uk

• https://www.gov.uk/government/collections/hm-revenue-and-customs-compliance-

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