Despite the critical nature of customs duty compliance, many SAOs inadvertently overlook their responsibilities in this area. The SAO accepts personal responsibility and liability for tax accounting, including customs duty. It leaves lots of unanswered questions. Why does it commonly slip through the net? What are the SAO’s obligations? How can the business achieve best practise without excessive time-implications?

What are the SAO’s obligations regarding customs duty?

  • Creation, validation and maintenance of the data items determining customs duty costs (e.g., tariff codes, origin, customs valuation adjustments, customs procedure codes etc.)
  • Appropriate security to protect master data and document retention
  • Ensuring the customs declarations include these controlled data elements
  • Evidence of corrective actions and audit trails
  • Audit trails through to paying for the goods and any refunds
  • Documentation of the customs procedures
  • Staff training or evidence third parties are appropriately qualified or experienced
  • Any authorisations are correct and additional obligations met (e.g. periodic returns for duty reliefs)

Why does customs duty slip through the SAO net?

One of the primary reasons for the oversight is a lack of understanding and the sheer complexity of the regulations.  Surprisingly, the professional qualifications required by SAOs do not cover customs duty, yet it is an area where small errors can have big consequences and the rules are constantly changing. This means that it can be challenging for SAOs to stay on top of all the latest developments and ensure that their companies are compliant.

Furthermore, compliance requires the co-operation of business functions outside of the SAO’s direct control, including logistics, procurement, warehousing, manufacturing and sales. These different departments may not fully understand the customs duty implications of their activities and there is likely to be a lack of communication between them and the SAO.

With so many departments involved, senior accounting officers may not have the visibility they need to ensure compliance.  The company’s information systems do not hold customs transactional data, which makes it difficult to see what’s going on.


What can the SAO do to address these issues with maximum time and cost efficiency?

First and foremost, companies need to recognise the importance of customs duty compliance and allocate the necessary resources to ensure it. This may mean investing in training programs for senior accounting officers and other employees, as well as dedicating more staff and budget to customs compliance.  However, the most cost-effective method is to leverage newly emerging technology. CAT360 is a new plug and play customs analytic software which streamlines the process of customs declarations, delivering considerable savings in time and money and eliminating the risk of errors.  It also allows real-time updates which is invaluable if you should find yourself called for HMRC audit.

Stuart Reid, Finance Director, Komatsu, commented:

We have developed our commercial and duty management systems significantly in order to help us maintain control, but still find ourselves relying on analysing substantial amounts of declaration data in Excel.  We can see the benefit in software systems that give clear visibility of KPIs and this is something we are looking at adopting in the future. CAT 360 software offers significant enhancements in terms of efficiency, error correction and maintaining an audit trail.”

As the global economy continues to become more complex, customs compliance will become increasingly critical to business success. By investing in resources, improving communication, and leveraging technology, SAOs can ensure that they are equipped to handle the complexities of customs duty compliance now and in the future.

If you would like further information on how to take advantage of duty suspensions, call Adam on 0121 403 3901 or click the link below to send an email now.

About Barbourne Brook

Barbourne Brook are a proactive team of customs duty planning experts with a wealth of knowledge and insight in the customs sphere, offering scalable solutions backed by industry-leading technology.

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+44 (0)1905 914 031


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