Policy & Compliance
• Information regarding company accountants and solicitors. In addition, Members may wish to engage the services of a credit checking agency and ensure that they conduct the relevant establishment checks. However, it should be noted that the party requesting the checks will, in the eyes of HMRC, still retain responsibility for its accuracy. In many ways it is about building up a basket of evidence on which to make a judgment call as to whether a business is established in the UK. Yes, it will take more time before business is onboarded and competitors will cut corners, but you have to ask yourself, “Is it worth taking the risk?” Fraud in the supply chain In the writer’s view, fraud has always been part of the supply chain. In the 1970s, shipments of unlabelled textile goods made in Hong Kong were shipped to the UK in one consignment. In another shipment in the consolidation ‘Made in England’ labels were shipped to be sewn into the garments. Also, to reduce duty payments, it was not uncommon for certain items to be shipped in component parts and re-assembled in the UK. However, the scale of such activity and the profits to be derived are much greater now than they have ever been. Unfortunately, the Customs agent, particularly when representing overseas traders, can find itself liable for the latter’s activities – a point that the former must be aware of. When conducting their own due diligence checks, Members cannot rely solely on government resources, which by its own admission does not provide all the information needed, and consideration must be given to what additional checks and questions are necessary to establish whether a company is established in the UK.
• Proof of residence or usual residence in the UK (for sole traders, etc), • Details of key staff, including job title (for certain authorisations such as the Fulfilment House Due Diligence Scheme, directors have to provide additional information such as their National Insurance Number), • A certificate of incorporation issued by Companies House, • Details of business activities and where they are carried out, including full address and postcode – checks can be made on Google Earth, • Details of where staff are employed and the work that they carry out, • Details of the physical premises owned or leased by the business, • Details of contracts, orders or invoices held or issued by the business, • Proof that the business has its own accounts – ask for copies, etc,
“ Members cannot rely solely on government resources
Meeting Members
The events also marked the retirement of outgoing Regional Consultant, Len Hobbs who has represented BIFA in Scotland since late 2016. An announcement regarding new regional representation will follow. Also joining Steve and Len at the two events was immediate past Director General Robert Keen.
New BIFA Director General Steve Parker is continuing his drive to meet as many BIFA Members in-person as possible, travelling to Scotland at the end of March.
During meetings in Glasgow and Aberdeen, Steve addressed those present detailing his vision for BIFA and his plans for future engagement with Members.
14 | May 2023
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