Managing cash flows through Customs warehousing

The use of Customs warehouses and rebate stores in South Africa is well entrenched and widely used.

The variety of categories of Customs warehouses and rebate stores is not always appreciated and fully understood. This may create exposure for both the operator of the warehouse and the auditors signing off on the financial statements where the risks associated with Customs warehouses are not recognised.

This article provides a bird’s-eye view of the Customs warehousing environment in South Africa.

Why use a Customs warehouse or rebate store?

The purpose of using Customs warehouses or rebate stores is almost without exception to defer or avoid the payment of import duty and VAT on such imports.

Storage warehouses normally serve to defer the payment of duty and VAT, while rebate stores may result in no VAT or import duty being payable on materials used for the production of specific products.

The purpose for which a facility is required must be established to ensure that the appropriate licence and approvals are obtained.

What are the licensing requirements?

A storage facility and a rebate store must be licensed with Customs and Excise, and must comply with very specific physical attributes as well as documentary processes.

Manufacturing rebate stores where goods are manufactured for the purpose of export (generally referred to in practice as toll-manufacturing operations) must also obtain a licence from the International Trade Administration Commission (ITAC) to manufacture the goods. The licence normally limits the extent or volume of the goods that may be manufactured in South Africa.

Which storage and manufacturing facilities are allowed?

Where goods only need to be stored, the goods are normally stored in a Customs and Excise storage warehouse (OS) or a special Customs and Excise storage warehouse (SOS).

A warehouse may either be operated by an organisation privately, or public storage facilities may be used.

Rebate stores are generally operated by the manufacturer at approved premises.

Documentary requirements

Each facility has specific physical and documentary requirements that must be complied with. Any deviation from these rules could result in duty and VAT becoming payable immediately or, in extreme cases, the forfeiture of the goods in the storage facility.

Conclusion

While the operating of storage or rebate facilities may contribute to enhanced cash flow in the overall supply chain, care should be taken to ensure compliance with the stringent rules to avoid exposure to risks that may be costly for the user.

Practitioners who wish to explore this topic in greater depth are invited to watch The Tax Faculty webinar on demand, Application Procedure for Warehouses and Rebates Facilities, presented by Christo Theron.

Related reading: RLA is here to stay; Valuation of goods for customs purposes not always as simple as it seems; Is VAT eating away at your cash flows?.

Frequently asked questions

Why use a Customs warehouse?

To defer, or in some cases avoid, import duty and VAT on goods until they are cleared for home consumption or exported.

What is the difference between a storage warehouse and a rebate store?

Storage warehouses mainly defer duty and VAT, while rebate stores may result in no duty or VAT on materials used to make specific products.

Do warehouses need to be licensed?

Yes. Customs warehouses and rebate stores must be licensed and operated under strict Customs control and record-keeping rules.

What risks should auditors consider?

Unrecorded duty liabilities, stock discrepancies and licence breaches can create significant exposure that should be recognised in the financial statements.

Build your expertise: to apply these principles in practice, explore The Tax Faculty’s Application Procedure for Warehouses and Rebates Facilities webinar on demand.

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