Processing the application: multi-site authorisations
Many traders have multiple sites of operation within the UK and may wish to operate each set of premises independently. Although the legal entity may decide to apply to have more than one site included in their CFSP operation the authorisation must be in the name of the legal entity.
Where a legal entity makes a CFSP application and the Head office is in one Business area whilst the trading premises are in another, care should be taken to ensure the trader is authorised by the most appropriate authorising office/r. In CITEX this is ensured by the application being ‘allocated’ by RIS to the Senior Officer (SO) for the appropriate area. There is little point in one Business area authorising a trader for whom they have the Head office, if the records, premises and goods are in another area. If, however, the Head office holds the records but the trading activities are carried out at a site in another area then the application should be allocated to the SO for the Head office location.
When an application for CFSP is received, it is vital that the authorising officer establishes the following before proceeding with the authorisation process:
- Has the application been made by the Head office for the legal entity?
- Does the application cover more than one site?
- Is it the intention for more than one site of the same legal entity to operate CFSP?
- How does the applicant intend to operate CFSP, ie one EORI for the whole legal entity or one EORI with individual branch references for each site? If individual branch references are required, each branch should be identified by an AI statement code in box 44 of the declaration. Statement code ‘BR’ plus a three digit reference number should be entered for importers and code ‘AG’ plus a three digit code should be entered for agents/declarants.
Authorisation and site control responsibilities
When an application for CFSP is received, it is vital that the HMRC office with responsibility for the trader’s Head office establishes communication with the offices responsible for the area in which the trader has indicated they wish to operate CFSP. The Head office should verify with each office that:
- no other CFSP applications covering that site have been submitted
- local staff have no knowledge of any past instances of serious or repeated non-compliance and
- any other authorisations to be operated alongside CFSP are valid (ie warehousing, etc).
Once it has been established that there are no barriers to the application being progressed, discussions should take place between all offices to ensure consistency of treatment for each site. Officers should agree whether:
- each site will be self-accounting (ie submit declarations under one EORI with branch identifiers)
- each site will maintain its own records (EIDR, TS, Warehousing)
- the trader’s Head office will submit declarations on behalf of all sites, under one EORI number, either with or without branch identifiers
- the records will be maintained at a central location
- what assurance work each office will undertake.
It is important to agree each of these issues at the outset to ensure that each office/r is clear on their responsibilities and that no controls slip through the net. If these issues are not resolved before the trader begins operating it may result in documents not being maintained correctly, officers not being assigned an appropriate amount of resource for control or officers not being able to access the necessary paperwork (ie papers in Scotland whilst the officer is in Southampton).