Sean Turner – VAT Specialist
DD: +44 (0)207 465 1908
Import VAT and duty relieved on medical supplies, equipment and Personal Protective Equipment (PPE) brought into the UK during the Covid-19 outbreak
HMRC recently announced that VAT and duty relief can be claimed immediately by organisations and bodies importing certain goods into the UK during the Covid-19 crisis.
This means that businesses importing relevant goods as below, can benefit from relieved import VAT and duty charges when declaring the goods for import into the UK from outside the EU. This will represent an ultimate saving on duty and cash flow advantage in respect of import VAT, where import VAT would otherwise have to be paid, or deferred, on import and reclaimed at a later date on the VAT return.
This applies to the following goods imported to free circulation:
- Goods for distribution free of charge to those affected by, at risk from, or involved in combating coronavirus
- Goods made available free of charge to those affected by, at risk from, or involved in combating coronavirus, while remaining the property of the organisations importing them.
The relief will apply to imports of PPE, other relevant medical devices or equipment for coronavirus.
In addition, the following also qualify for relief:
- Goods imported into the UK for donation or onward sale to the NHS
- Goods imported into the UK for disaster relief agencies to meet the needs of combatting coronavirus
If goods are loaned, hired out or transferred to an organisation eligible for the relief, the relief will remain in place as long as the conditions continue to be met. Currently, the relief applies until 31 July 2020.
What the goods cannot be used for
Note that, if the goods cease to be used by those affected by coronavirus, they cannot be loaned, hired or transferred for consideration, or free of charge, unless HMRC is notified. Import VAT and duty will be payable, if goods are loaned, hired or transferred to organisations or individuals not affected by coronavirus.
When completing the entry in CHIEF, relief must be claimed by using Customs Procedure Code (CPC) 40 00 C26 in box 37 and document codes 9AID and /or 9AIV and status codes JP or UP as appropriate in box 44.
Latest Update to the relief (06/05/2020)
HMRC updated their guidance on VAT and duty relief for imported medical goods at the end of April. HMRC have now given general approval to the following charitable and philanthropic organisations:
- those registered by the Charities Commission or the Office of the Scottish Charities Regulator
- state organisations which are devoted to welfare
The following, as long as they are non-profit making and their objective is the welfare of those in need:
- youth organisations
- clubs, homes and hostels for the aged
- orphanages and children’s homes
- organisations set up for the relief of distress caused by particular disasters in the Customs Union
- organisations concerned with the relief of distress generally (such as the British Red Cross Society or the Salvation Army)
Goods may also be imported on behalf of one of these organisations if for donation or sale, directly or indirectly, to them. However, if importing on behalf of one these listed organisations, authorisation must be obtained from the National Import Reliefs Unit (NIRU) by application form, available by email to firstname.lastname@example.org.
If the items have been imported on behalf of another organisation, to claim relief as importer, clear evidence must be held to demonstrate that the end user of the goods was an eligible organisation. The evidence must allow HMRC to trace the goods from initial import, through to ultimate end use. VAT and duty might become payable without this evidence.
The commodity code list for relevant goods has also been updated and will be kept under review.
Claiming relief on goods already imported
If you imported eligible goods on or after 30 January 2020, but did not claim relief, it may be possible to make a retrospective claim, again by application form from NIRU. A copy of the duty and VAT relief certificate and documents supporting eligibility for relief will be required.
A claim for overpaid import VAT must also be made by application and not by adjusting the VAT return and a statement made to this effect. If the C79 has already been received and the import VAT claimed on the VAT return, a claim for duty relief only should be made.
If an importer has restricted VAT recovery, already claimed on the VAT return, or plans to claim previously irrecoverable import VAT, a claim can be made for the full amount of VAT. However, the importer must adjust the claim on the VAT return to nil and provide a statement to this effect.
If you have any questions in relation to this guidance, please speak to a member of the VAT team.