CFSP14650 - Processing the application: group authorisations

Many large traders consist of groups of companies. It is not always easy to identify the legal entity in a group of company ‘names’ and some further research may be necessary to determine which member is ultimately responsible for the debts of the others. Some or all may be separate legal entities in their own right. Any registered limited company (ie whose name ends in 'Limited', 'Ltd', or 'PLC') that is capable of both suing and being sued should be individually authorised for CFSP. Such a company cannot be included as a branch office in the authorisation of any other legal entity. Cases of dispute are to be referred to the Solicitor (via the CFSP Facilitation Team) with appropriate background information.

If all the companies are separate legal entities the authorisation may take one of the following forms:

• each company within the group may be separately authorised to operate Simplified Procedures and have a separate system and a separate DAN. Each company would submit their own SDs and FSDs or would nominate a Direct Representative to do this
• one of the companies may act as a Direct Representative for the others and would transmit all SDs and FSDs. Each company would, however, be authorised to operate Simplified Procedures, each with their own deferment number
• one of the companies may take responsibility for applying for authorisation to operate Simplified Procedures. That company would need to be authorised as an IR. In this case only one company in the group need be authorised. (The TURN of the group member acting as the IR will be shown in box 14, the TURN of the group member/legal entity who owns the goods will be shown in box 8)
• one company may act as the importing member for the group. Only that company is authorised to operate Simplified Procedures and their TURN appears in box 8.

Some companies may consist of a single legal entity with many trading names or divisions. The legal entity may have separate TURNs to differentiate between the separate areas of the business. Legal entities that fit into this category may apply for authorisation using:

• One CFSP authorisation for the legal entity covering one TURN under which all imports for the legal entity will be declared.
• One CFSP authorisation for the legal entity, but the various TURNs belonging to each trading name/division are set up on CHIEF so that they can report their CFSP declarations separately. A separate FSD would be required for each ‘authorised’ TURN.