Duration of T2L

[Mistroma]

I guess that doesn't contradict what my friend said. He said that he couldn't find any reference to an expiry date but I didn't ask about the VAT side post-Brexit. He didn't understand why anyone would ask to see a T2L for a boat sailed into a country.

I guess he was saying that T2L did not have an expiry date when used as expected. I think HMRC will probably be less likely to commit to saying something about post-Brexit situation regarding VAT and a document not being used as intended in the first place.

OP just asked about a 2 month limit and my friend replied to that query. I didn't think to ask about Brexit as I would expect a "who knows" reply.

Posted also in lounge

Been told to day by broker that a T2L is only valid for two months, can anyone confirm this
Thanks

 

[greeny]

???? Potentially not? What does that mean? Maybe yes, maybe no?
Not really a straight answer is it.
So we all reapply for a new T2L in 2021? With the original date on but issued retrospectively after Brexit.
It's a nonsense.

 

[nortada]

Whilst on the subject of scams, is there any truth in the rumour that Wales is going to put a Covid tax on all pleasure boats in Northern Wales

I am told that the Vietnam-Taff want to tax rich boat owners to help defray the cost to poorer members of the community. I understand that the plan was hatched in Conway, who heavily endorse the idea because there are far too many people not paying their fair share to support the community.

 

[nortada]

???? Potentially not? What does that mean? Maybe yes, maybe no?
Not really a straight answer is it.
So we all reapply for a new T2L in 2021? With the original date on but issued retrospectively after Brexit.
It's a nonsense.

After 31/12/20, I suspect HMRC will no longer provide a T2L on request. I am amazed that they have been so helpful for so long?

If required to produce T2L in the brave new world, it should not be beyond the resourceful to produce a ‘T2L(Post Brexit Format)’?

Think this thread has probably gone as far as it can so bring on the next scam?

 

[Graham376]

I still go back to the question - why on earth does anyone think a T2L is better than in original invoice?
Boats before 1984?? just need some proof of the harbour they were in on the relevant date, nothing else.

I suspect if T2L docs issued by the HMRC are to be recognised after leaving, then it would need to be mentioned in the Brexit agreement - I cant see it getting in now!

I have never understood why two countries require a document which was never designed for the purpose. My own thoughts are that a UK issued T2L will cease to be valid on 31/12 as UK goods will no longer be in free movement afterwards. Invoices are still the best bet, along with proof of a boat being in EU on 31/12. With DTP, it shouldn't be hard to provide the necessary documents.

 

[Graham376]

Whilst on the subject of scams, is there any truth in the rumour that Wales is going to put a Covid tax on all pleasure boats in Northern Wales

Don't know about boats but I did hear they were going to double VAT on inflatable sheep.

 

[nortada]

I have never understood why two countries require a document which was never designed for the purpose. My own thoughts are that a UK issued T2L will cease to be valid on 31/12 as UK goods will no longer be in free movement afterwards. Invoices are still the best bet, along with proof of a boat being in EU on 31/12. With DTP, it shouldn't be hard to provide the necessary documents.

Getting a genuine original is always the difficult bit.

 

[greeny]

Don't know about boats but I did hear they were going to double VAT on inflatable sheep.

And wellies will be in short supply.

 

[Chris_Robb]

Fairly explicit, but I still dispute why people think the T2L is better than the original Invoice? Old boats before the VAT deadline date

I have never understood why two countries require a document which was never designed for the purpose. My own thoughts are that a UK issued T2L will cease to be valid on 31/12 as UK goods will no longer be in free movement afterwards. Invoices are still the best bet, along with proof of a boat being in EU on 31/12. With DTP, it shouldn't be hard to provide the necessary documents.

And if coming from outside the EU, say Turkey, some proof that you have not been away for more than 3 years! Marina receipt, E-TEPAI, Log books etc. Otherwise you will find they require TI! Its going to be a problem for quite a number in Turkey.

 

[Graham376]

And if coming from outside the EU, say Turkey, some proof that you have not been away for more than 3 years! Marina receipt, E-TEPAI, Log books etc. Otherwise you will find they require TI! Its going to be a problem for quite a number in Turkey.

The 3 year limit on UK RGR is fake news, there is no time limit for taking a boat back in the same ownership.

 

[Chris_Robb]

The 3 year limit on UK RGR is fake news, there is no time limit for taking a boat back in the same ownership.

Quite, it recognises that yachts go sailing around the place and in reality they have not been exported in our understanding.
This is the EU using laws never applied in the past to sod us up.
RGR has never ever applied to Yachts and was a tool to allow EU yachts back into the EU if they were in UK waters on the 31st Dec

 

[TernVI]

I still go back to the question - why on earth does anyone think a T2L is better than in original invoice?
Boats before 1984?? just need some proof of the harbour they were in on the relevant date, nothing else.

I suspect if T2L docs issued by the HMRC are to be recognised after leaving, then it would need to be mentioned in the Brexit agreement - I cant see it getting in now!

A T2L is an official opinon that the boat is 'union goods' at the time of issue.
The original invoice likewise.
Either is really only valid if there is a chain of ownership showing nothing has happened since to change the status of the goods.
I would want bills of sale and other evidence from the date of T2L or bill of sale right up to the present.
An invoice from 3 owners ago in 1995 wouldn't cut it.

 

[TernVI]

The 3 year limit on UK RGR is fake news, there is no time limit for taking a boat back in the same ownership.

The 3 year limit is not fake new, it's clearly in the law.
HMRC will 'generally' waive the limit if certain conditions are met.
Notice 236: Returned Goods Relief

 

[Graham376]

The 3 year limit is not fake new, it's clearly in the law.
HMRC will 'generally' waive the limit if certain conditions are met.
Notice 236: Returned Goods Relief

I spoke to the VAT Import and Export department who informed me that RGR was never designed for personal goods and my boat which has been outside the UK now for 14 years will have no problems.

The document you link to clearly says - This notice concentrates on the arrangements for re-importing commercial goods.

 

[Chris_Robb]

The 3 year limit is not fake new, it's clearly in the law.
HMRC will 'generally' waive the limit if certain conditions are met.
Notice 236: Returned Goods Relief

HMRC had to, in the withdrawal agreement, match the EU use of RGR, required to provide a legal way for EU owners to return with their yachts if they had been in the UK. I doubt whether it will ever be used in anger as no o e will be challenged on returning. This was the view of HMRC but they brought in RGR to provide the same legal certainty!

Export from the eurozone for a yacht is the act of sailing it abroad. Returning is the act of sailing back. You are exempt from looking your VAT status if you return within 3 years of export.

Now this has never ever been the establishe practice when a yacht sails abroad. This is made up mumbo jumbo from the commission. As far as the HMRC is concerned , it's like it always was. If it's sold abroad it's lost, but 3 years never entered the picture.

Yachts in Turkey will have an issue as Greece had already pointed out to the CA, that a yacht in Turkey for more than 3 years is f.....d.

 

[Chris_Robb]

I spoke to the VAT Import and Export department who informed me that RGR was never designed for personal goods and my boat which has been outside the UK now for 14 years will have no problems.

The document you link to clearly says - This notice concentrates on the arrangements for re-importing commercial goods.

CORRECT

 

[Sandyman]

Don't know about boats but I did hear they were going to double VAT on inflatable sheep.

Only on pre-owned & well used second hand ones

 

[Graham376]

Yachts in Turkey will have an issue as Greece had already pointed out to the CA, that a yacht in Turkey for more than 3 years is f.....d.

But, what about yachts whose owners can prove they have spent time in Greece most summers, thereby having returned to EU waters within the past 3 years? Surely, the clock should start the last time they left Greece?

 

[Chris_Robb]

A T2L is an official opinon that the boat is 'union goods' at the time of issue.
The original invoice likewise.
Either is really only valid if there is a chain of ownership showing nothing has happened since to change the status of the goods.
I would want bills of sale and other evidence from the date of T2L or bill of sale right up to the present.
An invoice from 3 owners ago in 1995 wouldn't cut it.

There are 2 issues here on loss of EU VAT Status.

The first is how strongly the EU Customs especially the horrible man in Kos -Greece- will interpret the 3 year rule. Will he just accept a Dekpa which shows that you were there last year and the year before, or will he just accept last year just a current years E-TEPAI. This of course could give the overstayers in Turkey a get out of Vat free card.
The second - and I would anticipate this to be more onerous, is on the sale of a yacht - to prove it still held EU Vat Status and UK Status (much easier). I think the buyer might smell blood and ask for total paperwork trail, in the hopes of money off the sale.....

Time will tell.

 

[Chris_Robb]

But, what about yachts whose owners can prove they have spent time in Greece most summers, thereby having returned to EU waters within the past 3 years? Surely, the clock should start the last time they left Greece?

Yes you are totally right. People just need to be aware that they might need proof - so dig out the paperwork and put it carefully aside.
There are a number I know who have been outside with no revisits for 5 years. They were hoping to get back this year and slip under the radar. There area couple that came back for 1 month last year... They should certainly try to get away with it, but I would advise them to go anywhere but Kos or Rhodes where the customs are notorious for extreme decisions.

I am trying to get an agreement with the Greeks on what and how it will be done by customs - I dont dare mention those overstayers. But there needs to be clear instructions across all customs offices, especially as we will need a Transit Log, all-be-it, with Vat Paid, an Unlimited TL. I am also hoping that the Greeks will scrap the current transit log which still requires checking in and out of every port, in favour of a form similar to the UKs C1331 form which 3rd Countries have to complete to come to us at the moment.