1. A CBR experience

2. Agenda Today’s case Post Brexit Pre Brexit - Proposal 1 under CBR
The CBR process experience
Taxpayers’ feedback

3. Order for Coating services
1. Todays’ case
Order for coated lenses
Order for Coating services 1
French
GroupCo UK
GroupCo
US company
Final client
Uncoated lenses
Coating
Coated lenses 2 3
Invoice for coating services
Invoice for supply of coated lenses (export from France in the French VAT reporting)

4. Order for Coating services
2. Post Brexit
Order for coated lenses
Order for Coating services 1 2
UK GroupCo
US company
Final client
French GroupCo
Uncoated lenses
Coating
Coated lenses
IPR customs regime
Invoice for coating services
Invoice for supply of coated lenses (export from the UK – sale abroad from French VAT perspective )

5. Voluntary joint liability
3. Pre Brexit – proposal 1 – More liability in exchange for no UK VAT registration French GroupCo
Order for coated lenses
Order for Coating services 1 2
UK GroupCo
US company
Final client
French GroupCo
Uncoated lenses
Voluntary joint liability
Coating
UK groupCo reports French Groupco’s
deemed IC-acquisition on its own UK number
Coated lenses
Invoice for coating services
Invoice for supply of coated lenses (sale abroad from French VAT perspective)

6. Order for Coating services
4. Pre Brexit – proposal 2 – Inspired by a longstanding German approach
Order for a uncoated lenses
Order for Coating services 1 2
UK GroupCo
US company
Final client
French GroupCo
Uncoated IR lenses
Coating
(1) Proof of export coated lenses
(2) Attestation “connection” in/out
Coated lenses
Invoice for coating services
All transport services
Invoice for supply of uncoated lenses (export from FRANCE reported for VAT purposes )

7. 5. The CBR process experience
2/06/2017 : Request posted to the French CBR contact with the UK CBR contact in cc.
27/09/2017 : Reply from the French authorities with French point of view. France does not reply to the need for UK VAT registration or not.
13/10/2017 : Call with the French CBR file responsible to ask whether the UK will say something too.
14/11/2017: Transmission of the UK reply by the French authorities. Good news, no UK registration needed for French GroupCo.
29/11/2017: Call with the French CBR file responsible noticing that the UK is clear on the “no UK registration needed” but France is not yet clear what to report in France then.
21/12/2017: Request to France for bringing clarity on the French side or make a joint decision.
19/02/2018:

8. 6. Taxpayer’s feedback
Thank you, France and the UK, for the goodwill to consider this case.
Good transparency in the process
Good contact with the French CBR file responsible at the phone.
Feeling that organizing a bilateral discussion moment between the UK and France is not as easy as it looks.
Introductory meeting with taxpayer may have been more efficient.
If France unilaterally confirms the French compliance requirements, given no UK registration is available for French GroupCo in both proposed scenarios, then it should be solved.

9. Thank you !