Hi all! HMRC updated Excise Notice 226 on Tuesday and have included seemingly new information about a transition period from Small Brewers Relief to Small Producer Relief. The exact wording in Section 8 is as follows:
SBR eligible beer produced before the 1st of August 2023 will be charged at that SBR rate even if released on or after the 1st of August 2023.
We’re working on implementing this into Breww now, and Barry Watts at SIBA is kindly helping us clarify this scheme with HMRC beyond the single sentence they have provided above.
However, our understanding is that this means beer eligible for Small Brewers Relief that was produced before the 1st of August 2023 will be charged at the rate it would have been charged at if dispatched before the 1st of August 2023.
This means any Small Brewers Relief beer will not be eligible for Draught relief, as it is now being charged using the old rates. To ensure that your customers can take advantage of the fact your existing SBR eligible beer can’t have draught relief applied and they can therefore sell the beer for takeaway, Breww will warn you if you try and dispatch an order where you’ve specified that draught relief should apply, but the order has SBR eligible beer assigned. This allows you to then go into the order and remove the requirement to apply draught relief, so that your customer receives an invoice with the “Draught duty relief has not been applied” message displayed, allowing them to sell the beer for takeaway. Or, alternatively, you could assign non-SBR eligible stock and save the old stock for a customer who requires the full rates to be paid.
To determine when beer was produced for the purposes of this transition scheme, Breww will use the Date & Time of a packaging action. Or for any delayed racking releases with a reason of Conditioning or Maturing, Breww will use the date it was released.
@adam-henderson This means that what we thought was the case no longer appears to be true! So there’s no need to pay the duty on your high-strength beer if you haven’t already done so, as the transition period means you will have to pay the old rates on it anyway.
We are keeping firmly on our toes with this one, and if we receive further clarity from HMRC that requires updates from us, we’ll implement them into Breww immediately. If any clarification from HMRC requires us to make changes, but we don’t receive this clarification until during August, we will update your existing August figures accordingly if required 