A Spotlight On Export Valuation
Strong & Herd LLP
Supporting international business! We provide practical training in the areas of export, import and customs procedures.
Export value, does it matter? In short, it does; although there are no duties or revenue at export, it is something that HMRC take very seriously.
Whilst there aren’t any export duties in the UK, VAT-registered companies are permitted to zero rate their exports, rather than incur the 20% rate of VAT, for which they must obtain official or commercial evidence.
Many companies believe they can declare a nominal value on their commercial invoice and subsequently on declarations when they export a sample or a free replacement item. There are also cases of companies deliberately undervaluing their exports, enabling the importer to pay fewer duties and taxes upon importation.
So, what is the HMRC legal definition regarding valuation at export? The Tariff quotes the following:
“The value to be declared is the cost of the goods to the purchaser abroad (or if there is no sale, the price the goods would fetch if sold to a purchaser abroad); it should include packing, inland and coastal transport in the UK, dock dues, loading charges and all other costs, profits, charges and expenses”.
For example, the export value should include any insurance and commission accrued on the journey up until the goods are deposited on-board the exporting vessel or aircraft. Outward sea/air freight, marine/air insurance, and any cash?or trade discounts to the purchaser abroad, must be deducted from the export invoice value.
For goods re-exported after process or repair in the UK, the value declared must include the charge for the process and the value of the goods when imported.
On the other hand, there could be a genuine reason why a product has a low export value. For example, a plastic vial that costs less than £10 to replace. However, be mindful that the eyes of an HMRC Officer could be drawn to low-value exports and request evidence from you to demonstrate how you reached that particular value.
HMRC officers can request further information at audit, such as bank statements to evidence the payments made for your exports. HMRC officers also speak to other Customs authorities via a mutual understanding agreement.
To look at it from another perspective, you may remember the Hoegh Osaka vessel that ran aground in January 2015 on its way from Southampton to Bremerhaven carrying high-end cars.??As the exporter of these vehicles, you should ensure that your insurance covers the total value of the goods in case such mishaps occur.
Anyone who has ever submitted an insurance claim will know that insurance companies are meticulous in requesting numerous forms of evidence to justify a lawsuit. Just imagine if
you’d deliberately undervalued the cars on your export declaration that the insurance company had requested.
In conclusion, whilst less complex than import valuation, export valuation is still essential in compliance with our declarations.
Think Export. Think compliance!
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