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SOURCE Ryan, LLC
DALLAS, Feb. 10, 2014 /PRNewswire/ -- The European Union has been discussing and negotiating a new customs code for many years. The Union Customs Code (UCC), as it is now called, was finally adopted on October 9, 2013 and went into effect October 30, 2013. Although the UCC is now published, no changes will occur until May 1, 2016 at the earliest, as the Delegated and Implementing Acts that provide the details have yet to be finalized. In January, the European Commission issued its draft proposals for the Delegated Acts (DAs) and Implementing Acts (IAs) that will support implementation of the UCC.
There are many changes in this first draft which will impact trade, some positively and some negatively. Other aspects will be financial and some both financial and operational. The most common is the removal of what is known as the "First Sale" valuation principle.
Under the UCC, to take advantage of such trade facilitative procedures, companies will be expected/required to meet the requirements of Authorized Economic Operator (AEO) as a minimum. Furthermore, while the scope of requirements for duty guarantees is increasing in some European countries, there will be an opportunity to reduce the level of the guarantee. The criteria and actual percentage of reduction have not yet been confirmed.
The Commission and Member States customs authorities accept that the May 1, 2016 deadline is very tight and as such have the opportunity within the UCC to phase in certain non-critical/essential procedures after this date over the period leading up to 2020. It is most likely that trade facilitation procedures, such as Centralized Clearance and Self-Assessment, will not be available on Day 1. However, for interested companies, the opportunity to operate a "pilot" for one of the procedures not formally available on Day 1 might become available. Participation in such a "pilot," while time consuming, would enable the participant to direct and influence the eventual requirements.
The May 1, 2016 deadline is fixed, and there is a planned timetable for the events (negotiations and adoption of the DAs and IAs) leading up to this date. However, should there be any delay, the time allowed for the latter events will decrease. While there will be some time for trade consultation, it will not necessarily be on all of the issues, and there will be little time to submit comments.
We are posting this development on our U.S. and global websites, so all of our Ryan clients are aware. This is a complex area, and we want to provide sufficient notice for your consideration.
Ryan is an award-winning global tax services firm, with the largest indirect and property tax practices in North America and the seventh largest corporate tax practice in the United States. Headquartered in Dallas, Texas, the Firm provides a comprehensive range of state, local, federal, and international tax advisory and consulting services on a multi-jurisdictional basis, including audit defense, tax recovery, credits and incentives, tax process improvement and automation, tax appeals, tax compliance, and strategic planning. Ryan is a three-time recipient of the International Service Excellence Award from the Customer Service Institute of America (CSIA) for its commitment to world-class client service. Empowered by the dynamic myRyan work environment, which is widely recognized as the most innovative in the tax services industry, Ryan's multi-disciplinary team of more than 1,600 professionals and associates serves over 9,000 clients in 40 countries, including many of the world's most prominent Global 5000 companies. More information about Ryan can be found at www.ryan.com.
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