Who handles import VAT reconciliation?
Agree a written handover: the bookkeeper collects evidence and matches entries, the broker investigates declaration discrepancies, and the accountant reviews VAT treatment and return figures. Name a business approver and an archive owner. Agree shipment paperwork support with Cambridge China Bridge.
Agree the work before handing over documents
Put the division of work in the engagement terms with your bookkeeper, accountant and broker. Name the person doing each task, their replacement, the delivery deadline and the person who accepts the handover. The allocation below is a suggested working arrangement. Ask each adviser to confirm what their fee and engagement actually cover.
When a broker imports on your behalf, HMRC requires written confirmation before they can proceed with a declaration using postponed VAT accounting. Keep that instruction alongside the broker’s acknowledgement. Use our import VAT guide for the tax background; this guide deals with who carries the reconciliation through to completion.
| Role | Agreed task | Handover evidence |
|---|---|---|
| Bookkeeper | Collect documents, match entries and maintain the exception log | Reconciliation with linked evidence and open queries |
| Broker | Supply declarations, investigate discrepancies and report correction progress | Written explanation and declaration or amendment evidence |
| Accountant | Review tax treatment, unresolved items and proposed return figures | Reviewed reconciliation and recorded treatment decisions |
| Business approver | Approve the identified return version and authorise submission | Dated approval and submission receipt |
| Archive owner | Keep the complete pack accessible and arrange adviser handovers | Document index, access details and handover acknowledgement |
Name who obtains each piece of evidence
Ask the bookkeeper to maintain a shipment register linking the supplier invoice, transport paperwork, customs declaration reference, import date and VAT evidence. Agree that the broker supplies declaration copies and explanations, while your purchasing contact supplies commercial documents. Identify who downloads the monthly postponed import VAT statement and who covers their absence.
HMRC requires you to download and keep a copy of each postponed import VAT statement. Ask the collector to save the original download, record its period and tell the bookkeeper when it is ready. Match statement entries to the shipment register and flag missing or duplicate records. For retrieval problems, use missing import VAT evidence.
Give unmatched entries an owner
Keep an exception log with the declaration reference, discrepancy, documents missing, named investigator, next action and agreed response date. The bookkeeper should separate missing paperwork from a declaration discrepancy or a bookkeeping error. For a missing statement entry, HMRC says to ask the agent to confirm that import VAT was allocated to the correct importer identification number.
Ask the broker to investigate declaration facts and the accountant to decide the return treatment. Keep the entry open until the explanation, supporting evidence and accounting action are recorded. A promise to investigate is not closure. Use broker declaration errors for the correction route, and escalate unanswered queries to the business approver before the agreed review date. For garment-specific queries, see children's clothing and junior kit VAT.
Approve the figures and the unresolved decisions
Ask the accountant to review the reconciliation against the proposed return, including recoverability, duplicated postings and period allocation. HMRC requires postponed import VAT to be accounted for in the return period covering the import date; normal input tax recovery rules still apply. Do not assume that the postponed amount is automatically recoverable in full. For marketplace purchases, see buying with a UK VAT number.
Give the business approver the identified return version, reconciliation and exception log. Record the accountant’s treatment and reasons for anything still unresolved, then obtain dated approval before the agreed submitter files. Save the submission receipt with that version. If an error emerges afterwards, refer to correcting import VAT return errors.
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Keep a handover trail the business can retrieve
HMRC’s archiving guidance says to keep VAT records for at least 6 years. Agree an archive owner and a retention schedule for the reconciliation pack. Keep instructions, original evidence, broker explanations, accounting decisions, approvals and submission receipts together, with links from the reconciliation to the supporting documents.
Choose a storage location the business can access when an adviser leaves. Before changing bookkeeper, accountant or broker, request the completed packs and open exception log, identify the incoming owner and obtain acknowledgement of receipt. Test retrieval of a shipment and its return approval. Record any missing files as handover actions rather than assuming the outgoing adviser holds them.
Frequently asked questions
Should my bookkeeper or accountant reconcile import VAT?
Agree that the bookkeeper prepares the matching and exception log, while the accountant reviews tax treatment and return figures. Confirm this scope in both engagements.
Who chases an import missing from my VAT statement?
Name the bookkeeper as query coordinator and ask the broker to investigate the declaration. Give the accountant the evidence and unresolved query before return review.
Who approves the import VAT figures before filing?
Use an accountant review followed by a named business approver’s dated approval of the identified return version. Separately name who submits and saves the receipt.
What should I get when changing accountants?
Request statements, declarations, reconciliations, open queries, treatment decisions, approvals and submission receipts. Record receipt and confirm the business can retrieve the files.