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Buying and Selling models to/from Europe


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On 22/01/2021 at 11:59, LimboBrit said:

I left the UK in '87 to live and work in the Netherlands. I married a Dutch lady and my kids have the Dutch nationality. As soon as the the referendum results were made known, not knowing what the consequences would be I decided to play safe and apply for Dutch nationality.

 

 

Similar-ish story here, I left the UK in 91 to live and work in the Netherlands, but in my case I married a French lady as we were both working for an international organisation. Unfortunately while we've talked about me applying for French citizenship, and I would if I could, the stumbling block is that my French is terrible and it's a requirement for the process. Because I was living in the Netherlands I put all my time into Dutch classes.

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12 hours ago, Enterprisingwestern said:

 

If you'd like to elucidate, cos I ain't got a frigging scooby.

 

Mike.

 

The critical thing to remember (and many still appear to be blissfully unaware )  that any item travelling from GB to the EU is now crossing a customs border, a situation we have been happily unencumbered by whilst the UK was a member of the EU and during the transition period.

Northern Ireland to / from  GB items are doing the same due to the way Northern Ireland is both in the UK and the EU customs territories at the same time

 

 

My understanding is as follows and I'm sure Admiles will correct me if I am wrong (these rules also apply if items are going from GB to EU but limits may vary)

 

1: If you buy something or several things in one transaction from an EU based trader that cost less than £135 in total , then the seller should be registered to pay UK VAT with the HMRC.

They will remove the local VAT from the price  and charge UK VAT, attach the appropriate customs labels and send it. They will  / should then pay the VAT collected on that transaction to HMRC

You will receive it as any normal parcel.

 

2: If the trader doesn't do this then you will be asked to pay VAT, duties  and any handling fee in order to have your parcel delivered. There is a risk here of paying both  the local EU country VAT and UK VAT (for instance from Belgium 21% Belgian VAT and 20% UK VAT. Adding an additional 45.2% on top of the excluding VAT price. i.e price +21% +20%)

 

3: If the total order is above £135, local VAT will be removed, parcel sent suitably labelled and  then the UK VAT and admin fee will need to be paid to take delivery.

 

(Again taking Belgium as an example and using sterling for simplicity. An item costing £200 excl VAT will cost £242 in Belgium incl VAT. Sent the the UK it will be £200 + 20% UK VAT + courier fee. Using Royal Mail that will mean £48 (20% VAT +£8 fee) to pay on delivery. Total extra cost compared to pre brexit of £6)

 

3A: If you buy through an online market place  rather than direct, then the VAT etc should be dealt with by the online market place operator

 

4: If the items or items were not made substantially in the EU or UK then there is also the possibility that an import tariff will need to be paid too (rules of origin). The rate will depend on how the product is classified from the huge (10,000 +) list of product classifications and what the % tariff applies to the item for the customs territory it is entering. 

Toy trains I believe attract  0% so Made in China shouldn't be a problem.

 

5: If a gift is sent to you across the border and the value exceeds the limits for whichever country it is being sent to (Not sure of limits but around the £35 mark for the UK but don't quote me) then there will be VAT,  tariff and fees to pay as appropriate. Below the limit nothing (this bit I am not 100% sure of, so you'll need to check for yourself)

 

6: If you shop personally and take the item in luggage there is a limit of £390 for bringing goods into the UK  (not including booze and fags which are calculated seperately.) Similar limits apply for items going to the EU but may be a lower limit depending on the country. You'll need to check.

I am  not sure how rules of origin regulations affect this.

 

7: Second hand or person to person sales face the same procedures.

 

8: People living in Northern Ireland are effectively still in the EU for customs and hence items crossing from NI to  GB face the same procedures and vice versa

 

All parcels crossing into NI, GB  or EU will need a custom label attached, which from memory (last time I filled one in was 1998) requires a list of contents and value at the very least.

 

 

The VAT rules for distant selling trade between EU countries will change in June / July with the trader needing to charge VAT at the rate of country of the purchaser and pay that VAT to the purchaser's country's tax authorities.

 

(In  theory a suitable computer program should be able to do this based on product barcodes and destination country with  VAT payments and acounting done automatically but I'm not holding my breath. )

----------------

As an aside to model railways

 

Taking meat, dairy, fruit, (with 5 exceptions including bananas, coconuts. pineapples and dorians)  vegetables, plants and derivative products into the EU is not allowed wthout the relevant phytosanitary certificate. Home made ham and cheese sandwiches don't tend to come with such a certificate. (This is a long standing rule that has been on display at EU borders for many years and is not a new thing as some will have you believe) 

 

Fish products have weight limts (20kg? or one fish if heavier)  as do any other allowable foodstuffs (2kg)

 

Bringing such items to the UK from the EU is allowed at present but it will all likely change in July.

-------------------
 

Where it gets really confusing is when the terms get used interchangably. Phrases such as tariff, customs duty, customs fees, duty and  excise duty seem to be used randomly to mean the same thing but it just serves to cause confusion when the term being used is changed part way through any guidance  without any apparent explanation

 

The bottom line is if you can find someone who is prepared to jump through the hoops and sell to you, then you may find yourself paying a lot more than the screen price + postage (20% + admin fee) to take delivery

OR

paying only a marginal amount more overall but the doorstep fee can be a bit of a shocker. 

(In the Belgian example  above, being  asked for £48 on the doorstep may seems like daylight robbery, but in the grand scheme of things  you've only had to pay an additional £8 compared to what you would have paid if the item was in your local shop at the same price)

 

 

Andy

(I've got a headache now)

Edited by SM42
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25 minutes ago, Ron Ron Ron said:

 

It also affects people living in EU member countries, buying stuff from the UK, so it's not limited to "overseas modelling".

 

 

.

 

Maybe a pinned guide in simplified terms would be useful.

 

Andy

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30 minutes ago, Barry Ten said:

 

Similar-ish story here, I left the UK in 91 to live and work in the Netherlands, but in my case I married a French lady as we were both working for an international organisation. Unfortunately while we've talked about me applying for French citizenship, and I would if I could, the stumbling block is that my French is terrible and it's a requirement for the process. Because I was living in the Netherlands I put all my time into Dutch classes.

I was exempt from following an “inburgeringscursus”. I speak fluent Dutch anyway so it wouldn’t have been a problem but I’ve seen some of the questions that are asked. I think a lot of Dutch folk would be struggling to answer quite a few of them

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43 minutes ago, Barry Ten said:

 

Similar-ish story here, I left the UK in 91 to live and work in the Netherlands, but in my case I married a French lady as we were both working for an international organisation. Unfortunately while we've talked about me applying for French citizenship, and I would if I could, the stumbling block is that my French is terrible and it's a requirement for the process. Because I was living in the Netherlands I put all my time into Dutch classes.

 

The advantage of your situation is that you are not living in France but are married to a French citizen, so your right to live in the EU anywhere but France is protected under freedom of movement rules for spouses.

 

Being one generation too far removed from an Irish passport, I'm pinning my hopes on becoming a naturliased Irish citizen after moving there using  freedom of movement rules. I'm hoping there won't be an Irish gaelic  language test. Polish is hard enough

 

Failing that, it's a begging letter to Andrzej Duda

 

Andy

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On 22/01/2021 at 13:56, admiles said:

 

Well technically he's charging UK VAT as he's collecting it on behalf of HMG and paying it to them!

 

 

I've an awkward suspicion he intends to pay the VAT to the Belgian Govt, not HMG - which is where I think he's misunderstood/decided not to follow the new rules

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3 hours ago, irishmail said:

FAO Mods,   could this thread be changed to Buying and Selling models to/from Europe?   

Reason I suggest this is like me there are quite a few English/UK citizens now living in the EU so this topic is of interest to all parties.

 

2 hours ago, bbishop said:

And should it be in Overseas Modelling  rather than German Railways?  Bill

 

The thread is also relevant to the many oo modellers in Ireland who purchase model railway items from the UK.

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44 minutes ago, SM42 said:

 I'm hoping there won't be an Irish gaelic  language test.

 

Ireland has two official languages,  Gaeilge (Irish) and English, so if you can speak either you should be ok for that part of the process.

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Well good news for me, Got a 24 Cobalts, The UK Retailer added no Vat to the invoice and it sailed through and landed with no extra charges, Just as I had hoped when Brexit was first mooted! Result! in 21% less cost and 20 notes a motor. 

 

Mind you the Tax Man is never far away is he!

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7 hours ago, irishmail said:

FAO Mods,   could this thread be changed to Buying and Selling models to/from Europe?   

Reason I suggest this is like me there are quite a few English/UK citizens now living in the EU so this topic is of interest to all parties.

I’m pretty sure I can’t do that so I’ll ask the boss!

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  • AY Mod changed the title to Buying and Selling models to/from Europe

Hello, yes this seems frustrating but that is the rules, taxes must be paid. I used to import model railways from the USA, for a very short period this was not taxed (VAT) or handling charges due. This was a honeymoon period of about 4 months on a monthly delivery. About 7 years later I moved premises and incorrectly thought that I would have another grace period. But no, I was being traced. Do not get me wrong we live in an honour tax system and I believe we should pay taxes due. It just makes Brexit more real!

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5 hours ago, Simaz said:

Do not get me wrong we live in an honour tax system and I believe we should pay taxes due. It just makes Brexit more real!

The discussion here is not about how to avoid paying taxes. It is about the administrative hassle and increase in cost of buying models across the UK border

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Coming back to CE mark, note that CE also stands for Chinese Export, and is often used as such. In the proper european CE mark, if the C is expanded to be a full perfect circle it should perfectly link to the E (which should also be possible to expand to a full perfect circle). If the C is not circular, or would not link to the E, then it is Chinese. However, I suspect the Chinese have realised this by now.

 

https://support.ce-check.eu/hc/en-us/articles/360008642600-How-To-Distinguish-A-Real-CE-Mark-From-A-Fake-Chinese-Export-Mark

 

 

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It appears as though several UK businesses have been advised to set up subsidiaries in the EU to avoid disruption.

 

"..... several say they have been told that setting up hubs in Europe would minimise the disruption, even if it means moving investment out of the UK".

 

I'm not convinced that this Brexit thingy has been thoroughly thought through.

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I've Spent the entire weekend helping to clear the backlog of Freight from the UK into Ireland.

 

Frankly from the paperwork I am getting I feel that  the Preparation that the UK Exporters took on board was next to Zero.

 

No Country of Origin mentioned on the paperwork - Cant Claim Preference 0% duty.

No UK COO Declaration in any shape or form. 

Vat being Levied on exports to Non Regd Cnee - That chap is gonna get a nice surprise when he sees another 21% on the cost of his exercise machine.

Wrong EORI numbers or No EORI Numbers.

No Incoterms

No Weights

and it goes on.

 

All this is contributing to a massive back log of Cargo in our UK Hubs and much of it cannot be processed correctly into the EU.

 

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The problem we have found is that the Government advice and guidance in the run up was not clear to non-specialist or fragmented, and every bit of advice from the freight industry was nuanced in terms of “subject to a deal”.

 

As only a certain percentage of our business goes to Europe it was a question of how much resource do you throw at something that was subject to change and deal or no deal, and how much do you spend reacting to the reality once the situation was clear.
 

We have sufferered more from the meltdown of our courier than our own lack  of preparation. Even now I am authenticating EORI numbers only for them to claim they are invalid 6 hours later....

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1 hour ago, Georgeconna said:

I've Spent the entire weekend helping to clear the backlog of Freight from the UK into Ireland.

 

Frankly from the paperwork I am getting I feel that  the Preparation that the UK Exporters took on board was next to Zero.

 

No Country of Origin mentioned on the paperwork - Cant Claim Preference 0% duty.

No UK COO Declaration in any shape or form. 

Vat being Levied on exports to Non Regd Cnee - That chap is gonna get a nice surprise when he sees another 21% on the cost of his exercise machine.

Wrong EORI numbers or No EORI Numbers.

No Incoterms

No Weights

and it goes on.

 

All this is contributing to a massive back log of Cargo in our UK Hubs and much of it cannot be processed correctly into the EU.

 

I used to have to provide certificates of origin for items made from steel. Hard enough at times when steel coil was being imported and exported.

There was a system for regular parts to some customers  by which each load was delivered, but payment, including any tax and duty, was only made every three months.

I presume that such easy going methods are no longer acceptable. 

I also dealt quite  bit with NATO, either one off orders or through a catalogue for various standard items. I am curious as to how organizations such as NATO will fit in under the new system.

Bernard

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2 hours ago, Georgeconna said:

I've Spent the entire weekend helping to clear the backlog of Freight from the UK into Ireland.

 

Frankly from the paperwork I am getting I feel that  the Preparation that the UK Exporters took on board was next to Zero.

 

 

 

In fairness George.  The final government instructions for exporters was issued at 17:00hrs 31/12/2020 - just 6 hours to react and set up systems.  I am not sure that the problems lie solely with the exporters.  Some of it though is basic stuff to those in the know.

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1 hour ago, Andy Hayter said:

In fairness George.  The final government instructions for exporters was issued at 17:00hrs 31/12/2020 - just 6 hours to react and set up systems.  I am not sure that the problems lie solely with the exporters.  Some of it though is basic stuff to those in the know.

 

I take that and tbh a quick google search for what's required will set you right on most simple stuff, The Foodstuff and Chemicals are a different matter. The Transition for customs should og been gradual really.

 

I must admit it is a right ol mess, Exporters Still charging VAT, Advising Intra EU invoice on the invoice too. Nuts.

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2 hours ago, Andy Hayter said:

In fairness George.  The final government instructions for exporters was issued at 17:00hrs 31/12/2020 - just 6 hours to react and set up systems.  I am not sure that the problems lie solely with the exporters.  Some of it though is basic stuff to those in the know.

 

This to me is why politicians are clever but stupid, clever enough to negotiate a deal but too stupid to realise things can't change overnight and leave things as they were for a period of time whilst everybody concerned gets to understand what's going on.

 

Mike.

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