Tag Archives: vat-structure

VAT Simplification (We can but hope)

By Marcus Ward 13 November 2017

This month The Office Of Tax Simplification has published a document called “Value added tax: routes to simplification”. This includes 23 recommendations on how VAT may be simplified in the UK. This is the first Office of Tax Simplification review to focus specifically on VAT and it takes a high level look at areas where simplification of either law or administration would be worthwhile.

The report specifically covers the following areas:

VAT registration threshold
VAT administration
Multiple rates
Partial exemption
Capital Goods Scheme
The option to tax
Special accounting schemes

The dominant issue that came out of the report is the level of turnover above which a business is required to pay VAT, known as the VAT threshold. At £85,000, the UK has the highest VAT threshold in the EU. The report considered a range of options for reform, in particular setting out the impact of either raising or lowering the threshold to avoid the current “cliff edge” position (many business restrict growth in order to avoid VAT registration, creating a “bunching” effect. For example, lowering the threshold may create less drag on economic growth but would bring a larger number of businesses into the VAT system. Alternatively, a higher threshold could also result in less distortion but it would clearly raise less tax.

Legislation

It was noted that since the introduction of VAT in the UK, the relevant legislation has grown so that it is now spread across 42 Acts of Parliament and 132 statutory instruments while still retaining some of the complexities of the pre-1973 UK purchase tax system.

Brexit

The report notes that: unlike income taxes, the VAT system is largely prescribed by European Union rules, so Brexit may present an opportunity to consider areas which could be clarified, simplified, or just made easier. It is not clear at present how Brexit will unfold so this review does not embrace aspects of the VAT system which are part of the Brexit negotiations, such as financial services, or focus specifically on cross-border trade.

Recomendations

The summary of the 23 recommendations are reproduced here:

The government should examine the current approach to the level and design of the VAT registration threshold, with a view to setting out a future direction of travel for the threshold, including consideration of the potential benefits of a smoothing mechanism.
HMRC should maintain a programme for further improving the clarity of its guidance and its responsiveness to requests for rulings in areas of uncertainty.
HMRC should consider ways of reducing the uncertainty and administrative costs for business relating to potential penalties when inaccuracies are voluntarily disclosed.
HM Treasury and HMRC should undertake a comprehensive review of the reduced rate, zero-rate and exemption schedules, working with the support of the OTS.
The government should consider increasing the partial exemption de minimis limits in line with inflation, and explore alternative ways of removing the need for businesses incurring insignificant amounts of input tax to carry out partial exemption calculations.
HMRC should consider further ways to simplify partial exemption calculations and to improve the process of making and agreeing special method applications.
The government should consider whether capital goods scheme categories other than for land and property are needed, and review the land and property threshold.
HMRC should review the current requirements for record keeping and the audit trail for options to tax, and the extent to which this might be handled on-line.
HMRC should establish a target to update guidance within a short, defined, period after a legal change or new policy takes effect.
HMRC should explore ways to improve online guidance, making all current information accessible, and to gauge how often queries are answered by online guidance.
HMRC should review options to reduce the uncertainty caused by the suspended penalty rules.
HMRC should draw greater attention to the facility for extending statutory review and appeal time limits to enable local discussions to take place where appropriate.
HMRC should consider ways in which statutory review teams can deepen engagement with business and adviser groups to increase confidence in the process, and for providing greater clarity about the availability and costs of alternative dispute resolution.
HMRC should consider introducing electronic C79 import certificates.
HMRC should consider options to streamline communications with businesses, including the process for making payments to non-established taxable persons.
HMRC should looks at ways of enhancing its support to other parts of government (for example, in guidance) on VAT issues affecting their operations.
HMRC should review its process for engaging with business and VAT practitioner groups to see if representation and effectiveness can be enhanced.
HMRC should explore the possibility of listing zero-rated and reduced rate goods by reference to their customs code, drawing on the experience of other countries.
HMRC should consider ways of ensuring partial exemption special methods are kept up to date, such as giving them a limited lifespan.
The government should consider introducing a de minimis level for capital goods scheme adjustments to minimise administrative burdens.
The government should consider the potential for increasing the TOMS de minimis limit and removing MICE businesses from TOMS.
HMRC should consider updating the DIY House builder scheme to include clearer and more accessible guidance, increased time limits and recovery of VAT on professional services.
HMRC should consider digitising the process for the recovery of VAT by overseas businesses not registered in the UK.

Next Steps

The Chancellor of the Exchequer must now respond to the advice given.

Commentary

A lot of the areas identified have long been crying out for changes and the recommendations appear eminently sensible and long overdue. As an example, the partial exemption de minimis limit has been fixed at £7500 pa for 23 years and consequently the value of purchases it covers has reduced significantly with inflation. A complete read of the report with prove rewarding as it confirms a lot of beliefs that advisers have long suspected and highlights areas the certainly do require simplification. I am particularly pleased that the complexities of both partial exemption and TOMS have been addressed. Fingers crossed that these recommendations are taken seriously by the government and the Chancellor takes this advice on-board. I am however, not holding my breath. It is anticipated that the early indications of the government’s thinking may be set out in the next Budget.

VAT: Distinction between goods and services. Mercedes Benz Financial Services case

By Marcus Ward 17 October 2017

In the CJEU case of Mercedes Benz Financial Services (MBFS) the issue was whether certain supplies where of goods or services.

Technical Background

Before looking at the case, it is worthwhile considering the difference between goods and services and why the distinction is important. For most transactions the difference is clear, although sometimes (such as in this case) it is not immediately apparent. A starting point is that services are “something other than supplying goods”. Difficulties can arise in areas such as; provision of; information, software and, as MBFS discovered, Hire Purchase (HP)/leasing.

The distinction is important for two main reasons:

VAT liability – Goods and services may have different VAT rates applicable
Tax point – goods and services have different tax point rules, see here

The difference between HP and Leasing arrangements:

In an HP agreement the intention is usually for the ownership of the goods to pass when the final payment has been made. The transaction therefore relates to a supply of goods. If title to goods does not pass, this is leasing and represents a supply of services.

Case Background

MBFS offered certain contract purchases which were similar to many personal contract purchase deals for vehicles. These featured regular monthly payments with a final balloon payment. In the MBFS arrangements in question a significant difference to “usual” personal contract purchase agreements was that the balloon payment represented over 40% of the price of the car and payment of this fee was entirely optional.

The EU rules set out that there is a supply of goods where “in the normal course of events” ownership will pass at the latest upon payment of the final instalment. Consequently, the focus here was on whether the optional final payment meant that in the normal course of events the ownership of the car would pass to the customer.

Decision

The CJEU decided that the supplies were those of services rather than goods. This was based on the fact that, although the ownership transfer clause is an indicator of the transaction representing a supply of goods, there was a genuine economic alternative to the option being exercised. The circa 40% of the car price was a significant amount and it did not immediately follow that all customers would make this final payment. It was observed that in a “traditional” HP arrangement making the final payment was the “only economically rational choice”. This meant that the supply was one of services.

VAT Impact

As this was ruled to be a supply of services, output tax was not due from MBFS at the start of the contract (as would have been the case if the supply had been one of goods). This results in a significant cashflow saving.

Commentary

Any business which provides vehicles via HP or leasing arrangements should review its supplies and contracts to determine whether it can take advantage of this CJEU ruling. We are able to assist in this process.

VAT HMRC Updates

By Marcus Ward 12 October 2017

HMRC has updated some of its guidance. This includes: VAT manuals (HMRC internal guidance), VAT Notices and VAT Information Sheets and Revenue and Customs Briefs.

Full details here And a brief summary below:

VAT manuals

VAT Land and Property/Construction

VATLP24750 – Supplies between landlords and tenants; provision of finance for the purposes of the option to tax anti-avoidance legislation

VATLP23500 – Guidance on the option to tax anti-avoidance legislation

VCONST15250 and VCONST15610 – Guidance on the differences between care homes and a hospitals

VAT Education

VATEDU53400 – Guidance on “closely related goods” in relation to education services following the case of Brockenhurst College (please see here)

New and revised VAT Notices

702: imports

701/49: finance

700/45: how to correct VAT errors and make adjustments or claims

700/58: treatment of VAT repayment returns and supplements

702/7: import VAT relief for goods supplied onward to another country in the EC

714: zero rating young children’s clothing and footwear

New VAT Information Sheets and Revenue and Customs Briefs

VAT Information Sheets

Revenue and Customs Briefs

Please contact us if any of the above affects you , or you have any queries.

New Customs Bill White Paper – VAT implications

By Marcus Ward 12 October 2017

A new Customs Bill White Paper has been issued.

As a result of the Brexit vote new domestic legislation is due to enter Parliament later this autumn which will provide for most negotiated outcomes, as well as a contingency scenario.

This Bill will be referred to in this paper as the “Customs Bill”. The purpose of the White Paper is to set out the government’s approach to the Bill. It sets out how the current customs, VAT, and excise regimes operate for cross border transactions, why the Bill is necessary, and what the Bill will contain.

Unfortunately, although being “sold” as containing concrete details, unsurprisingly there is nothing particular of substance. I shall refrain from adding any political comments, but just to observe that any process will be confusing, complex, and very unhelpful for businesses.

Good luck everyone…

VAT: Extent of zero rating for a construction by a charity

By Marcus Ward 9 October 2017

Latest from the courts

In the First Tier Tribunal (FTT) case of The Trustees of Litton & Thorner Community Hall the issue was whether certain construction works were a completion of an initial build or whether they were an extension or an annex to a pre-existing building. And if an annex, whether it was capable of functioning independently from the existing building and whether there is a main access to the annex.

Background

The appellant began construction of a hall in 2008. It was intended that the hall would be available for a school to use and also for it to be available at for village use and other activities, such as by local youth clubs and a scout group. There was no dispute that the original construction was zero rated via VAT Act 1994, Schedule 8, Group 5, item 2 (The supply in the course of the construction of a building designed for a relevant charitable purpose).

A decision was made to install ground source heat pumps to feed the heating system. However the space occupied to accommodate the system meant that there was insufficient storage space in the hall. So at the time of construction, but before planning permission was obtained, it was decided with the builder that a steel joist should be incorporated within the east wall of the hall in order to facilitate the necessary support and access when the envisaged storage facility was added. The additional planning permission was granted in November 2011, three years after building work commenced. The facility was eventually able to be used when work was completed in 2014. The delay was caused (not surprisingly) by funding issues. It was the VAT treatment of work relating to the addition of the storage area which was the subject of the appeal, with HMRC considering that it was either standard rated work to the building or was a standard rated extension to it.

Technical background

The provisions relevant to the appeal are VAT Act 1994, Schedule 8, Group 5, Notes 16 and 17. It is worthwhile taking a moment to consider these in their entirety:

Note 16

For the purpose of this Group, the construction of a building does not include

(a ) the conversion, reconstruction or alteration of an existing building; or

(b) any enlargement of, or extension to, an existing building except to the extent the enlargement or extension creates an additional dwelling or dwellings; or

(c) subject to Note (17) below, the construction of an annexe to an existing building.

Note 17

Note 16(c) above shall not apply where the whole or a part of an annexe is intended for use solely for a relevant charitable purpose and;

(a) the annexe is capable of functioning independently from the existing building; and

(b) the only access or where there is more than one means of access, the main access to:

(i) the annexe is not via the existing building; and

(ii) the existing building is not via the annexe.

The Appeal

The Trustees appealed on two separate and distinct bases:

(1) That the additional building was the completion of the original building and neither an extension nor an annex to it. It was their case that the temporal disconnect between the two building processes must be seen in the factual context, with particular reference to the decision to put in a lintel to allow the building to be completed when additional monies and planning permission were available. Additionally, alongside this fact was that the appellant was a non-commercial organisation and so things could not progress as expeditiously as they might have done if those things were being undertaken by a commercial organisation.

(2) The second basis is that, in any event, the additional building is zero rated by reference to paragraphs 16(c) and 17 of Group 5 to Schedule 8. It was the appellant’s case that the additional building is an annex intended for use solely for relevant charitable purposes and it meets the conditions set out in paragraph 17(a) & (b).

Decision

The FTT decided that the work was subject to zero rating. Not only was it part of the original construction (albeit that there was a significant time period between the building original work and the work on the storage area) but also, even if the storage area is considered as being separate, it was ruled that, on the facts, it was an annex rather than an extension, so it also qualified for zero rating on this basis.

Commentary

The date a building is “completed” is often an issue which creates significant disputes with HMRC, not only for charities, but for “regular” housebuilders. I have also encountered the distinction between an annex and an extension representing a very real topic, especially with academy schools. Even small changes in circumstances can create differing VAT outcomes. My advice is to seek assistance form a VAT consultant at the earliest stage possible. It may be that with a slight amendment to plans, zero rating may be obtained in order to avoid an extra 20% on building costs which charities, more often than not, are unable to reclaim.

Links to what we can offer to schools here, and charities here

Additionally, our offering to the construction industry here

VAT: Separate or composite supply? The Ice Rink Company Ltd case

By Marcus Ward 4 October 2017

Latest from the courts – Appellant on thin ice?

In the first Tier Tribunal case of The Ice Rink Company Ltd the issue was whether supplies of admission to ice skating rink and the hire of children’s ice skates – where sold as a package were single or multiple supplies. This is yet another separate/composite/compound supply case.

As a background to the issue please see previous relevant cases here here and here (in fact, this case was referred to in this hearing).

The issue of what is a single supply and what must be split as separate supplies seems to be neverending and HMRC appears to have an appetite to challenge every moot position through the courts.

Background

As anyone who has been ice skating will be aware (I tend to avoid the places not least as a result of not wishing to demonstrate my total lack of balance or skill) you can take your own skates, or hire skates for that session. In this case, the costs were £8 to use the rink or £10 with skate hire. The sole issue in the appeal was whether, when the appellants sold a “package deal” at £10 allowing a child to skate and to hire skates, it made a single supply or two separate supplies. If they made separate supplies, the £2 hire of skates to children is zero-rated. If it is a single supply the whole package is standard rated.

Decision

The judge decided that there were two separate supplies and that the skate hire supply could be treated as zero rated. This decision was based on a number of factors put forward by the appellant and which may be summarised as:

Skating with skate hire is a mixed supply, as the supply of skates is distinct and separate from the supply of admission
Around half the customers wishing to skate brought their own skates and some customers hired skates without paying to skate (at club sessions when a club had hired the rink and they needed skates for their club members). The hire of skates was therefore capable of being carved out from a single supply
A single “package” price is not determinative – in this case is it clear to the customer that they have freedom of choice and the components are available separately
Despite what HMRC said, it is clear that the skate hire is additional and optional
Neither supply is predominant and neither ancillary (as HMRC have previously accepted)
There was physical separation between the admission booth and the skate hire zone

The decision helpful included the following observations: “In our view… it is plain that in this case there are two supplies, a supply of the use of a skating rink and the supply of hire of ice skates. Neither is ancillary to the other as they both can be, and are, purchased on their own. Far from it being artificial to split the package into two, that is precisely what is in effect done in a substantial percentage of the appellant’s transactions with those using its facilities.” And “From the customers’ viewpoint a consumer of the package is getting the two things they want. The two elements are dissociable, not because of any spatial separation between the ticket office and the skate hire booth, but because that is the only appropriate way of looking at the supply of the elements.” And “…a substantial percentage of customers will choose to buy one or other of the element but not both, and that it is possible that the same customer may at one time buy a package and at another buy only one of the elements. Therefore it makes no sense to say that the elements are not dissociable when on a majority of the occasions that users enter the reception to use the rinks they choose only one of the two main elements, entry to the rink.”

Commentary

A sensible decision based on the facts. There does not seem to be an end to these types of cases as the decision is always based on the unique facts of each situation. It is difficult, if not impossible, to draft legislation which covers every type of scenario. Consequently, case law is very important in this area and the lead cases of CPP and Levob are the most cited. This case further illustrates that HMRC are not always correct in reaching a conclusion on multiple/composite supply cases and there is usually value in challenging their determinations. I would also say, from experience, that a review of a business’ activities can often identify such contentious areas and as always, getting it wrong can either result in an assessment and penalties, or mean that a business is paying too much VAT – not something that sits easily with me!

VAT: Latest from the courts – partial exemption attribution

By Marcus Ward 4 October 2017

In court about courts…

In the First Tier tribunal (FTT) case of The Queen’s Club Limited the issue was whether certain input tax was attributable to the company’s taxable activities or, as HMRC contended; to both its taxable and exempt income (so that it was residual). If HMRC were correct an element of the input tax would fall to be irrecoverable via the appellants’ partial exemption calculation. A brief guide to partial exemption here

Background

The Queen’s Club (The Club) is a well-known members’ tennis club in West London. The Club’s tennis facilities are world-class and each year the Lawn Tennis Association hires the Club’s courts to put on the Aegon Championship which is a precursor to the Wimbledon tournament and attracts many of the world’s leading players. It makes exempt supplies of sporting services to its members and also makes taxable supplies of food and drink in its bars and restaurants. It incurred VAT on the costs of refurbishing the bars, restaurant and café facilities on its premises. The Club considers that it is entitled to a full credit for input tax on those expenses as they were wholly attributable to the taxable supply of catering.

The Club’s revenue comes primarily from the membership fees that it charges. For the year 2012-13 the annual membership fee was £1820. By becoming a member of the Club, a person obtains the right to use both its sporting and non-sporting (catering) facilities. It was decided by the FTT that the Club had a discretion, but not an obligation, to provide the café etc to its members, however it was accepted that most members do not use the social facilities. It was agreed that the membership fee was consideration for an exempt supply of services closely linked with sport for the purposes of Value Added Tax Act 1994, Schedule 9, item 10. The Club also receives five main sources of taxable income:

Fees from the LTA to use its courts for the Aegon Championship
Sales of food and drink from restaurant and bars
Sales of sporting and other goods
Provision of the use of the restaurant and bars, usually with catering
Rental income for certain other rooms

The decision

There was no dispute that there was a direct and immediate link between the refurbishment of the restaurant and bars and taxable supplies made from them. The question that divided the parties was whether there was also a direct and immediate link between the refurbishment the exempt membership supplies.

The judge decided that “In short, viewed objectively, what members obtain when they join the Club is a right of access to world-class sporting facilities together with such additional facilities as the Club decides, in its discretion, to offer. The focus is on the sporting facilities…” and that, viewed objectively, the renovated bars and restaurant are a means by which members are able enjoy the Club’s sporting offering. The overall conclusion was that there was no direct and immediate link between the renovation goods and services and exempt supplies that the Club made.

The decision was that the Club was entitled to credit for the full amount of input tax that it incurred.

Commentary

This case demonstrates that care is always required when costs are attributed to a business’ activities. This is especially important when the costs are significant; particularly when they are incurred on land and property. There tends to be a lot of “debate” with HMRC on such matters and slight nuances can affect attribution. These type of costs are often covered by the Capital Goods Scheme, so care must be taken over a ten year period which adds to the complexity. As always, when considering land and property transactions it pays to obtain professional advice as mistakes are costly. A brief guide to land and property issues here

VAT due on property search fees? Whether they are disbursements

By Marcus Ward 25 September 2017

Latest from the courts – Brabners LLP

In the First Tier Tribunal case of Brabners LLP (Brabners) the issue was whether an external search agency used by the appellant correctly treated its supplies as VAT free, and if this was the case, whether the VAT free treatment continued to the appellant’s clients by way of a disbursement.

This is an interesting case and may create historic difficulties for conveyancing solicitors.

Background

Brabners is a law firm with a real estate department. It offers conveyancing services, both to buyers and sellers, in relation to proposed property transactions, for both commercial and residential property. In order to fulfil certain legal requirements, it used an external third party entity to obtain online property searches. The Appellant stated that it uses the online system for the majority of its searches (as opposed to a postal search carried out by employees of a Local authority, or a personal search at the Local Authority’s premises). The online search is not carried out by the Appellant, but rather, a specialist online search agency (‘Searchflow’) engaged by Brabners. Searchflow obtained the required property searches from the Local Authority’s digitised or dematerialised files and registers, and passed those results back to Brabners.

Searchflow invoiced the appellant for the cost of obtaining access to documents without the addition of VAT. Brabners treated this as a disbursement and invoiced its clients for the same amount without VAT.

The issues were:

Should the supply by the search agency be subject to output tax?
Was there a single or multiple supply?
Whether the charge to the end user of the services should be treated as a disbursement in respect of the search element
Which party consumed Searchflow’s services? (Brabners, or Brabners’ clients)

Note: the disbursement position is only (practically) relevant in this case if it was decided that the search fee was VAT free. Local Authorities now (from March 2017) charge VAT for searches, so the impact is only likely to impact on past situations.

Contentions

The main thrust of the Brabners’ argument is that the firm was requested, or expressly authorised, to obtain a search on the client’s behalf. Consequently, this meant that the firm was simply acting as the client’s agent, and the report belongs to the client. Brabners, argued that the search fees qualified as a disbursement for the purposes of VAT, and were not part of the otherwise taxable supply. It also argued that this separate treatment is intelligible and sensible. HMRC formed the view that the relevant payments cannot be treated as a disbursement as all the tests to do so were not met. For a guide to disbursements and the relevant tests please see here

Decision

The judge decided that the relevant expenses paid to Searchflow had been incurred by the appellant “in the course of making its own supply of services to” (its client) “and as part of the whole of the services rendered by it to” (its client). Therefore Brabners had consumed the service such that it could not be a disbursement. This point in this case proves academic as it was also, unsurprisingly, decided that Searchflow’s services were standard rated, so even if it were a disbursement, the VAT would still be payable by the appellant’s client.

Consequences

All firms which carry out conveyancing should review the VAT treatment of searches. If they have erroneously treated similar transactions as disbursements in the past, this is likely to require correction. Clearly, HMRC will be alive to this decision and it is anticipated that legal firms will be the subject of close inspection.

This case may also mean that third party search entities may be issuing retrospective VAT invoices or work which was previously treated as VAT free. This needs to be recognised and arrangements in place to recover any input tax incurred.

We are able to assist conveyancing firms with a review of the VAT position in light of this case.

VAT – Do as HMRC say…. and if you do… they may still penalise you!

By Marcus Ward 13 September 2017

Can you rely on a VAT ruling received from HMRC when they have been provided with full information in writing?

You would like to think so wouldn’t you? And in the past, you have been able to.

However, the long standing protection from assessments for deemed underdeclared VAT as a result of incorrect advice or actions by HMRC has been withdrawn. This was commonly known as “Sheldon Statement” protection. HMRC now state that there are some circumstances in which their primary duty is to collect tax according to the statute and it may mean that they can no longer be bound by advice they have given. Despite all the publicity of their National Help Line and Advice Centre, plus the clearance procedures introduced to assist taxpayers with their obligations, HMRC can still renege on their advice! Even if you are fortunate enough to actually get a decision from HMRC (which is increasingly difficult and frustrating) you can’t necessarily rely on it. This is the case even if you have provided full information in writing (as required) and made a comprehensive disclosure of your position.

This makes it even more important to avoid errors and the increased risk of VAT penalties and interest. Details of the penalty regime here

This leaves the question as to whom businesses can rely on for accurate, cost effective VAT saving advice and guidance on getting VAT right? The answer, clearly, is to contact their friendly local VAT consultant…

Brexit: The future of Customs arrangements

By Marcus Ward 21 August 2017

In a paper called Future Customs arrangements: A Future Partnership Paper the Government have given us some idea of what the UK’s relationship with the EU may look like after Brexit.

It is a paper which is part of a series which sets out the key issues and forms part of the Government’s stated vision for the relationship (called a “partnership” in the document) and is said to explore how the UK and EU will “work together” with respect to Customs. The aim is to facilitate the “most friction-less trade possible in goods between the UK and the EU”. It is noted that this approach is purely “aspirational” and represents the first steps in exploring the position. However, it does inform on the Government’s thinking. The two main approaches may be summarised as:

The Streamlined Arrangement

A highly streamlined customs arrangement between the UK and the EU, streamlining and simplifying requirements, leaving as few additional requirements on EU trade as possible. This would aim to;

continue some of the existing arrangements between the UK and the EU
put in place new negotiated and potentially unilateral facilitations to reduce and remove barriers to trade
implement technology-based solutions to make it easier to comply with Customs procedures

This approach involves utilising the UK’s existing third country processes for UK-EU trade building on EU and international precedents, and developing new innovative facilitations to deliver as friction-less a Customs border as possible.

A New Partnership

A new customs partnership with the EU, aligning the UK’s approach to the Customs border in a way that removes the need for a UK-EU Customs border. One potential approach would involve the UK mirroring the EU’s requirements for imports from the rest of the world where their final destination is the EU.

This is of course unprecedented as an approach and could be challenging to implement and the UK Government will look to explore the principles of this with business and the EU.

The document also considers that the Government would seek to introduce an interim period for implementing changes to Customs arrangements.

Discussions with affected businesses will continue before the publication of a Customs Bill in the autumn.

We will monitor this situation and bring you information on any developments. In the meantime, those businesses which carry out cross-border transactions in goods may want to review their current procedures in anticipation of the changes which will surely be introduced in one form or another.

Alas, as with anything Brexit related, nobody can be sure what the future holds and there will be a great deal of uncertainty until we know the actual outcome and consequently, the impact on business.