BDO's regional customs duties team can support your business by providing a high level "health check" of your customs routines.

1. CUSTOMS HEALTH CHECK
Customs health check - why now?
Regardless of the final Brexit outcome, the last
few months have brought customs duty to the
forefront of public attention.
In anticipation of Brexit, HMRC has undertaken a
significant recruitment drive for Customs
Officers. As a result, UK businesses should now
expect to see a lot more focus and attention
from HMRC on customs duty. It is expected that
this renewed attention from HMRC on customs
matters will take place regardless of whether
the UK leaves, or remains, in the EU.
HMRC customs audits
What does this mean for businesses who import
and/or export goods? First and foremost, it
means a likely increase in the number and
frequency of HMRC customs audits. These could
be multi-day visits by HMRC to ensure that a
business is paying the correct amount of customs
duty and import VAT and is compliant with
customs legislation.
As a starting point, HMRC will look at customs
declarations that businesses have submitted
(through their freight forwarders or by
themselves) to identify errors which have led to
underpayments of customs duty and/or import
VAT. HMRC will also ask businesses about their
current levels of customs procedures and
controls, in particular how they manage third
parties, such as freight forwarders, and ensure
the accuracy of the customs data that is
submitted to HMRC in the business’ name.
Implications
The implications of a poor customs audit for a
business can be severe. Financially, HMRC can
raise customs duty and import VAT assessments
going back three years and issue civil penalties
of up to £2,500 per error.
More importantly, historic non-compliance can
prevent a business from being authorised to
operate duty saving opportunities such as
customs warehousing and inward/outward
processing reliefs, as well as benefiting from any
waivers/reductions in duty guarantees. It can
also jeopardise new/renewal applications for
Authorised Economic Operator (‘AEO’)
accreditations which may become critical for
post-Brexit cross-border goods movements.
Why you should act now
If we carry out a review now and identify errors
that you then disclose to HMRC voluntarily
before HMRC carry out a customs audit then:
 You will not be subject to any civil penalties
(up to £2,500 per error)
 You will ensure that your current/future duty
saving reliefs and/or AEO accreditation are
not put at risk, ie because HMRC will not
have the opportunity to ‘discover’ the errors
that you have identified and then voluntarily
corrected
 We can help you to correct your current
customs procedures to stop future recurrence
of the errors that we identify.
Why you should use BDO
BDO has a team of customs specialists, including
an ex-HMRC Customs Officer who until recently
was responsible for reviewing the customs affairs
of some of the largest importers/exporters in
the UK, who can undertake a customs health
check on your business.

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What we would do
Understand your supply chain to build company
import/export profile by reference to:
 Location of suppliers/customers
 Incoterms (shipping terms) used in contracts
with the above
 Type of materials/goods imported/exported
 Commodity codes used
 Processing activity in UK, EU, Rest of World.
Review MSS data (HMRC customs data taken from
customs entries for imports/exports submitted in
your name by your freight forwarders) to:
 Identify anomalies in MSS data against your
company’s import/export profile
 Investigate anomalies through a review of
individual customs declaration paperwork
(‘C88s’) and, if necessary, retrospectively
address errors in customs declarations
through customs declaration amendments.
Confirm scope of use of third-party service
providers by analysing:
 Number and identity of freight forwarders
and other third party logistics parties used
 Roles and responsibilities of the above.
Conduct interviews with relevant company
personnel to establish current procedures and
controls around customs compliance.
If special procedures/duty reliefs (eg customs
warehousing) are utilised, review terms of
authorisations against current practice.
What you would receive from us
We would provide you with a concise, non-
technical summary of our findings and
recommendations (eg make a voluntary
disclosure to HMRC of errors identified) using a
traffic light system organised according to size
and urgency.
Meet our Customs Duties team
Juliet Wallwork
Tel: 0121 352 6423
Juliet.wallwork@bdo.co.uk
Juliet leads BDO’s regional Customs Duties team. She
has over 18 years’ experience in customs, excise and
international trade matters.
She has previously worked in both the UK and the Far
East for Big 4 companies, dealing with trade
compliance and cost savings.
Nick recently joined BDO. He has previous experience
as a Customs and International Trade Tax Specialist
with HMRC. Working with the UK’s largest importers,
Nick has in-depth knowledge of HMRC audit
processes, giving him unique insight into identifying
customs risks and improving compliance.
Nick Newton
Tel: 0121 352 6366
Nick.newton@bdo.co.uk
Chantal Tanner
Tel: 0121 352 6312
Chantal.tanner@bdo.co.uk
Chantal works with clients to help them gain relevant
accreditations and authorisations, investigate HMRC
rulings, perform health checks and assist with
compliance. Prior to this, she has gained three years
experience in the Risk & Advisory Services team and is
ACA qualified.