Ms Celine O'Neill:

I will pick up on the two aspects Senators O'Reilly and Gallagher asked questions about in relation to payments. Mr. Harrahill mentioned that 12,000 businesses have applied for an economic operators registration and identification, EORI, number this year. Once one registers for that customs number, one is automatically assigned a trader account number, TAN. It is from that account that the payments for any customs, duties or VAT are taken. There was confusion in the early days that the EU-UK Trade and Cooperation Agreement meant zero tariffs and quotas on all goods being imported from the UK, whereas in actual fact it only relates to goods of a UK origin. There are difficult and specific rules that relate to each product in order to avail of that zero tariff rate. That was the first difficulty that traders were having. They mistakenly thought that all goods imported from the UK would have zero tariffs payable and they then got a bill that they were not expecting in some cases. In other cases, they just did not claim it.

I mentioned the postponed accounting for VAT earlier. One must indicate on a declaration that one is availing of that postponed accounting. The same applies when one is claiming a preferential tariff rate. One has to indicate that on the customs declaration and that was not happening in the early days. We sent out some communications about that and that eased things for some people.

The way we try to think about it is that many of goods are moved by a lot of different people, for the same companies even, and the goods might arrive in at different times. Senator O'Reilly mentioned out-of-hours arrivals. While all of the State agencies are operating 24-7 in Dublin Port and on extended hours in Rosslare Europort, not all customs agents and brokers are. Where goods arrive out-of-hours and difficulties are encountered, there can be delays in rectifying the problem until customs agents come back on stream, maybe the following morning. Difficulties can be minimised by making sure there is sufficient money in the person's TAN account. Senator O'Reilly referred to a case where a haulier was moving goods on behalf of another business. In that instance, it was the TAN account of the business that was being used which did not have sufficient funds. That, in turn, delayed the entire shipment and vehicle. In those cases, the haulier itself will have a TAN account so it could use its TAN account and then it would be fully in control of what funds are in there. It could get the trader it is moving the goods for to pay the money over to it in advance, which would give it more control.

The way we tend to think about this is that it is similar to a person setting up direct debits from his or her account to all come out on the first day of a month. A person in that situation then has no say in the order in which those payments are made. All that is known is that it is necessary to have the full amount in the account on the first of the month to cover all the bills which will come in. That is the kind of scenario we are seeing.

Companies can do three things: they can see if they meet the requirements for claiming a zero-rate tariff, and indicate they wish to claim that tariff on the declaration; indicate they wish to avail of postponed accounting for the VAT element; or consider whether a deferred payment account would work well for them.