BRITISH INTERNATIONAL FREIGHT ASSOCIATION

Transcription

1 BRITISH INTERNATIONAL FREIGHT ASSOCIATION Minutes of Customs Policy Group Minutes of the Customs Policy Group Meeting held at The Baltic Exchange, 38 St Mary s Axe, London, EC3 8BH. The Meeting was held on the 27th April 2017 commencing at hours. 2. Competition Statement The BIFA competition Statement was read out at the commencement of the meeting 3. Presentation by BIFA Director General regarding amendments to BIFA Standard Trading Conditions A presentation was given regarding forthcoming changes to BIFA STC s, which had been agreed after consultation with the Legal and Insurance Policy Group, solicitors and insurers. These amended STC s with detailed guidance on the amendments would be advised to all Members when they were issued. The key messages were that:- There were no significant changes to the core structure and content of the STC s but that there were some additions and amendments to exiting clauses The STC s were the rules of the game highlighting the rights and responsibilities of the parties to the forwarding contract In order to rely on them the Member had to incorporate them in their contracts. 4. Agree the Minutes of meeting of 2 nd February The meeting agreed that the Minutes were an accurate reflection of the above meeting and were duly signed by the Chair. 5. Matters Arising from the Minutes of the 2 nd February There were two matters arising from the previous Minutes AP 1:-Agenda item 5. BIFA Training Update This was covered under action point 6. Training Update of the current agenda AP 2-Agenda item 8. BEIS Consultation BIFA Secretariat confirmed that, the Association had submitted to BEIS the response approved by the Customs PG relative the main regulatory issues facing the industry, the Department acknowledging receipt.

2 BRITISH INTERNATIONAL FREIGHT ASSOCIATION Minutes of Customs Policy Group 6. BIFA Training Update An overview of the good progress made by BIFA in developing the Freight Forwarding Apprenticeship was given. It was noted that since the introduction of the Apprenticeship Levy had been introduced in 2017, that in effect business was self-funding this scheme. At the moment, there are several logistic related Apprenticeships being proposed, BIFA s had been approved because it focused on international trade and Customs. Members had been actively involved, having input into the subject matter to be included in the various modules covering the modes and specialisms. It was noted by some Customs PG Members who had contributed into that the Apprenticeship would be relevant and practical. Further consideration would have to be given relative to what additional support could be given to individuals in their career path by BIFA. 7. BREXIT Generally the Customs PG agreed with the current position paper. However, it was noted that the likely issues surrounding port health should be emphasised. It was believed that the main issues to be addressed were:- Potentially the increase in checks if EU goods needed to be inspected at the border A current lack of Border Inspection Points Staffing issues There was a discussion regarding the impact on the UK of a reversion to WTO rules. These required that a customs declaration is made, although the timing and format are not defined. There was a discussion relating to the payment of VAT and support for the proposal to re-introduce postponed accounting. It was noted that post BREXIT, that nobody was certain how many customs entries would be presented to Customs, although it was noted that the current estimate was that it would be in the region of 250 million declarations per annum. Alternatives to the current procedures were discussed, and the AFSS voiced their support for implementing some form of Self-Assessment as outlined in the UCC, which is line with current BIFA policy. It was noted that current statistics showed that there were a 188K UK companies engaged in international trade only traded with EU Member States. Approximately 70% to 80% used intermediaries to move cargo etc. The potential skill shortages both within Customs and the Trade was highlighted, and there were concerns how this gap could be filled, although technology would provide part of the solution. 8. Outcome of the Fulfilment House Consultation As a result of lobbying by Trade, including BIFA, HMRC had considerably modified their initial proposals, which would reduce the burden on trade.

3 BRITISH INTERNATIONAL FREIGHT ASSOCIATION Minutes of Customs Policy Group 9. Transfer of Residence The Current problems were discussed, which were causing significant problems for people moving their goods to the UK and forwarders carrying and clearing those goods. BIFA would continue to highlight issues to the NCH in an attempt to resolve the issues. 10. Any other business The meeting was advised that:- Entry to BIFA s awards had been:- o Simplified and would be free o Submission would be made shorter A joint meeting is being organised with UKWA to cover key joint industry matters

4 Updates for Customs Policy Group 27 th April 2017

5 BIFA Training Update Agenda item 6. International Freight Forwarding Apprenticeship Operative Level 3 equivalent to an A Level qualification Suggested replace word Operative with Specialist 19 th April meeting with subject matter experts Emphasis to create practical and relevant qualification May 2017 public consultation on BIFA s draft apprenticeship qualification Aim to submit by 15 th May to Department of Education June 2017 once Standard approved work with training providers re apprenticeship delivery and end point assessment methods.

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7 Fulfilment House Consultation Agenda item 8 This fraud is costing HM Treasury approximately 1 to 1.5 billion per annum. From the evidence given during the Consultation approximately 25% of forwarders/logistics providers are acting as a Fulfilment House. During the Consultation term developed Third country goods fulfilment house business Main problems with initial proposals were:- Definition of a Fulfilment House was very broad including most warehouse and transport activities Also requirement for customs agent to check a register of Fulfilment Houses which was seen as being onerous and not adding to compliance

8 Fulfilment House Consultation Agenda item 8-cont d Emphasis shifted to activity and particularly the VAT status of goods after the Consultation The 2017 Finance Bill states;- Carrying on a third country goods fulfilment business (1) For the purposes of this Part a person carries on a third country goods fulfilment business if the person, by way of business (a) stores third country goods which are owned by a person who is not established in a Member State, or (b) stores third country goods on behalf of a person who is not established in a Member State, at a time when the conditions in subsection (2) are met in relation to the goods. (2) The conditions are that (a) there has been no supply of the goods in the United Kingdom for the purposes of VATA 1994, and (b) the goods are being offered for sale in the United Kingdom or elsewhere.

9 Fulfilment House Consultation Agenda item 8-cont d No reference in the Finance Bill 2017 is made for customs agents being required to check the online register for Fulfilment Houses. HMRC have accepted that they are responsible for controlling this trade Companies carrying on a third country fulfilment business have to be approved by HMRC A Register of all such companies will be maintained and publically available But a person does not carry on a third country goods fulfilment business if the person s activities within subsection (1) are incidental to the carriage of the goods. It will be a offence to carry on the business activities of a Fulfilment House without being approved.

10 Transfer of Residence Agenda item 9 Changes were initially introduced in Q4 2016, but not fully implemented until 1 st April 2017 due to BIFA s intervention. Main problems with new procedures are:- Significant change, failure to differentiate between RGR and ToR Language issues Procedures not clear :- Post or Electronic application? IT systems delivered late Significantly higher demand than expected, cars and pets etc included Current situation NCH as of 26/4 were processing postal applications from the 3 rd and electronic ones from the 12 th April. Additional staff Review processing procedures

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