“Importer of Record” status needs to be clear before claiming VAT off a C79 Import Statement.
HMRC’s Brief 2/19 “Import VAT deducted as input tax by non-owners” here.
It concerns input tax deducted incorrectly by businesses who do not own the goods being imported, despite being the importer of record and receiving the C79. The example of ‘non-owners’ used in HMRC’s update is toll operators acting on behalf of foreign clients. These businesses receive raw materials from abroad on behalf of their client and then process the materials before redistributing them in the UK or abroad. Although these toll operators have acted as importer of record and obtained the C79, they never own the goods and so are not entitled to recover the VAT.
There will not be any retrospective action taken by HMRC where the toll operator acted in good faith, but HMRC will not accept such VAT deductions from 15 July 2019.
It highlights the need to have clarify on who can recovery VAT off c79 Import VAT Statements.
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