David Miller

  • Relevant Qualifications: BTEC on Safety & Security Assessments (Section 5) for Authorised Economic Operator


David has 25 years’ experience within the Customs, VAT & AEO fields firstly as an Officer for 12 years within HM Customs & Excise (as it was then) and since 1999 as an indirect tax consultant. As an officer in HMRC David visited businesses to undertake Customs & VAT audits to ensure that they were compliant with the Customs & VAT legislation. Having been a gamekeeper he has now turned poacher and uses his experience to proactively assist businesses make the most of the Customs & VAT systems.

Because David has worked both within HMCE and as a consultant he understands both the commercial aspects of International Trade & HMRC requirements. This means that not only does he provide practical and understandable advice but because he ‘speaks the same language’ as HMRC he can represent businesses in a manner which produces the best outcome for clients.

As a Customs consultant this involves assisting businesses understand not just their compliance obligations but available opportunities to reduce their import duty and VAT bills so that they pay neither too much nor too little duty, especially as import duties are often a ‘sticking tax’ so directly affect bottom line profit if dealt with incorrectly. Recent client work includes:

  • Providing advice on the duty & VAT implications of importing from non-EU countries on a practical level such as Customs declaration awareness, liaising with freight forwarders, need for commodity codes so that businesses fully understand what they need to consider when importing
  • Undertaking reviews for clients on all Customs matters mainly in the UK but with some EU businesses
  • Helping clients with the implementation and operation of a Customs Warehouse
  • Advising clients on the successful operation of IPR including retrospective IPR
  • Advising on Valuation of imports including what should be included in the Customs Value and what can be excluded, specifically work on Buying Commission
  • Assisting clients with Tariff Classification so that they declare the correct commodity code for duty purposes
  • Advising on the rules of origin for specific products in order that clients can use Preferential Duty Rates with comfort
  • Assisting a number of clients on obtaining and operating End-Use Relief
  •  Representing clients when dealing with HMRC both on dispute resolution and obtaining rulings such as BTIs to ensure best possible outcome results

In addition, as a VAT consultant David undertakes a lot of work in the complex International VAT arena ensuring that VAT is correctly dealt with both in respect of imports, exports and intra-EU trade and his experience in this field is unique given that many VAT advisers do not know anything about Customs and many Customs consultants have limited VAT knowledge.

Recent work in International VAT includes:-

  • ·       Assisting clients with ensuring they are aware of rules regarding the zero rating of exports;
  • ·       Assisting clients obtain VAT cash flow savings by using reliefs such as Onward Supply Relief;
  • ·       Where clients import or trade via other EU countries assisting with the VAT implications of such transactions

AEO – more recently with the advent of AEO, David has also been involved on a practical level assisting businesses that are either considering or who wish to become AEO authorised. This involvement has included undertaking the requisite Assessment Reviews for both the Customs & ‘Section 5’ Safety & Security parts of AEO authorisation as well as assisting with the successful authorisation as an AEO operator.

Given the complexities of AEO David provides practical advice to ensure that the process in becoming authorised is as painless as possible and this advice ranges from initial advice as to what AEO is and how it can benefit a business so that an informed decision can be made with regards authorisation (or not), through to undertaking the Assessment Reviews and right through to managing the whole AEO authorisation process if desired by a client.

David obtained a BTEC in Section 5 Safety & Security Assessments for AEO from EdExcel in December 2011.

Contact Strong & Herd
to discuss your requirements
0161 499 7000
0161 499 7100
Strong & Herd LLP, Manchester International Office Centre
Styal Road, Manchester, M22 5WB