The following Value Added Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
If a business stores goods in the UK for sellers established outside of the UK (EU for supplies made before 1 January 2021), it may need to apply for the fulfilment house due diligence scheme (FHDDS). Details of the scheme and how to apply can be found below.
Businesses that store goods where the following criteria apply will be required to register under the scheme:
where the goods are imported (from a non-EU country prior to 1 January 2021)
the goods are owned by, or stored on behalf of, a person established outside of the UK (outside of the EU prior to 1 January 2021)
the goods are being offered for sale and have not been sold in the UK previously
the goods have been released into free circulation after being stored under a customs regime
HMRC emphasises that businesses should register if they meet the relevant criteria even if they do not consider that they are a fulfilment house or are registered with HMRC for other schemes that requires the business to undertake due diligence in respect of its customers.
Businesses that undertake the following activities are not required to register under the scheme:
the goods stored are owned by that business
the main business activities are transporting goods and those goods need to be stored temporarily as part of the overall transportation services
Fulfilment Businesses Regulations 2018, SI 2018/326
These rules are also not applicable to goods that are stored under a customs arrangement and are therefore not in free circulation in the UK. However, businesses will need to apply when the goods are released into free circulation if it continues to store those goods and they’re still offered for sale.
Fulfilment houses that are required to register for the scheme must apply before they start to trade. Failure to apply before commencing trade will result in the business being denied the right to trade as a fulfilment house and a penalty
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