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HMRC internal manual

Senior Accounting Officer Guidance

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HM Revenue & Customs
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Senior Accounting Officer Main duty: Reasonable steps: Example 4 - Customs Freight Simplified Procedures

The examples in SAOG14510 - 14515 illustrate some situations where reasonable steps are taken. The examples illustrate the point but are not exhaustive.

Example 4 - Customs Freight Simplified Procedures

The situation is similar to example 3, see SAOG14512, but here the process involves two declarations. There is an initial declaration (Simplified Frontier Declaration) containing information necessary to clear the imported goods through port inventory and Customs systems. This is followed, at a later date, by a second declaration (Supplementary Declaration) to provide the full declaration for Customs purposes. The goods may move into a different regime where the customs duties are paid at a different time. These declarations can be produced by a third party or by different people throughout the business. Reasonable steps could include:

  • obtaining assurance about the validation process for all data items to confirm that they are declared correctly, completely and in accordance with the law, as well as of the maintenance processes for the data via regular review of standing data
  • clearly documented and tested security and access levels allowing staff or third party personnel to generate or change data
  • ensuring that staff are appropriately trained for their role or that third parties are appropriately qualified and experienced to undertake any activities
  • review of the Authorisation document to ensure that the correct legal entity etc. remains authorised and no impacting systems changes have occurred
  • obtaining assurance about reviews of the declarations to confirm completeness of payment, accounting and Customs Declaration in accordance with the law
  • evidence of accounting for Customs Duty payments or refunds
  • evidence of documentation - CFSP Authorisation from HMRC, FSD/SD schedule or reconciliation as appropriate.