Given the advent of the new Customs law and the fact that businesses who look to use Customs Reliefs, e.g. a bonded warehouse, will possibly be required to lodge a security come June 2016, it is interesting to note that we are coming across HMRC seemingly taking a hard line approach in that they are already looking for security as a standard measure.
Our recent experiences is that their line on several businesses who are seeking to implement bonded warehouse status is that the business has 'failed' HMRC's 'solvency criteria' although they refuse to give specific reasons why, merely citing that this is 'not in the public domain' on the basis that businesses could manipulate their figures if they knew the criteria.
In addition, prior to June 2016, they are already looking at businesses who have a bonded warehouse or other duty savings measures to see if they should pay a security so it looks like AEO is front and centre again especially as the provision of security is quite onerous.
Action Points:- For businesses that already use duty suspension reliefs it will be worth reviewing processes, systems and financial statements to see how secure they already are.
For businesses contemplating using such a scheme, consider the financial position prior to doing any real work. Again we can assist.