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UPDATE: Yes I know its a Saturday and everyone is talking about Tier 4 but we have news on the Northern Ireland piece. Bear with me this could be a long. THREAD 1/12 https://twitter.com/Mulk_Lloyd/status/1339885987774799872
Lets start with a GB
manufacturer who moves a car to NI and sells it to a NI dealer (who is a separate company). From 01 Jan a declaration will be needed for the GB-NI movement. 2/
manufacturer who moves a car to NI and sells it to a NI dealer (who is a separate company). From 01 Jan a declaration will be needed for the GB-NI movement. 2/
Now the GB manufacturer will make the declaration (via TSS predominantly) as they have the expertise and systems knowledge to provide the information as they export globally today already. The NI dealer has none of this, they sell cars. 3/
What we have been waiting on is the "at risk" piece. Will automotive goods moved from GB-NI attract a tariff? Well this is where we have new information. There are two ways to avoid goods moved from GB-NI being deemed "at risk"... 4/
1. Goods will not be at risk when both the UK and EU charge 0% tariffs on them.
Well most automotive goods attract a tariff so this won't work. How about the second way? 5/
Well most automotive goods attract a tariff so this won't work. How about the second way? 5/
2. The NI Command Paper stated a "UK Trader Scheme" will be developed which allows companies to declare their goods "not at risk". Just what we need! Well... 6/
There are 2 ways to be authorised under the Scheme.
a. The biz is established in NI
b. The biz is established in GB and:
i. carry out customs in the UK
ii. have a fixed place of biz in NI
iii. have indirect representative in NI (such as the TSS) 7/
a. The biz is established in NI
b. The biz is established in GB and:
i. carry out customs in the UK
ii. have a fixed place of biz in NI
iii. have indirect representative in NI (such as the TSS) 7/
If we look back at the second tweet the manufacturer will not meet a. as they are established in GB. They also will not meet bii. as they do not have a fixed place of biz in NI, remember the NI dealer is a completely separate company. 8/
Lets hope the UK and EU agree an FTA then right? Well that does not solve everything. In a deal scenario using the UK Trader Scheme removes origin requirements. Without access to the scheme GB manufacturers are going to need to prove origin for 100's of GB-NI movements. 9/
The other unknown is what if the GB-NI movement does not meet the origin rules in the UK-EU FTA (if one is agreed) are tariffs then due in deal scenario on the GB-NI movement? Likely. 10/
This leaves the tariff rebate mechanism. Well this will not be in place for 01 Jan so any duty paid on GB-NI movements could not be reclaimed anytime soon putting companies in a weak cashflow position, presuming they pay the duty and do not pass this on to the consumer. 11
What a can of worms this is with 13 days to go. END
