Follow the goods, not only the business label: where were they, were they validly under suspension, and what event brought that suspension to an end?
Deferral remains tied to licensed premises, movement, authorisation, records and guarantee. If goods are released for consumption, lost without evidence or the document chain breaks, tax may become due.
Choosing the right route comes before calculation because timing and liability differ across local production, import and suspended storage.
This is not a lawful way to avoid licensing. The producer must register and license the production premises; production outside them does not prevent tax liability or the consequences of non-compliance.
Tax may remain suspended while the goods stay within the licensed arrangement, are recorded in stock and no event ends suspension.
Tax is collected through customs before release unless the goods validly enter suspension for a licensed tax warehouse.
Ordinary storage does not put paid goods back into suspension. Evidence of origin and tax payment should be retained.
The actual movement and its evidence control the result; simply calling goods 'stock' or placing them in a building used as a warehouse is not enough.
Producing or importing goods outside suspension.
Removing goods from the warehouse to the local market or consuming them there.
Holding untaxed goods without a valid suspension arrangement.
Loss or damage under suspension unless the licensee proves causes beyond its control through the Regulations Art. 5(5) procedure: immediate notice, then the form on the day after notice.
Failure of a consignment to arrive or failure to close its movement permit.
Suspension can continue during an authorised movement, but the sender's responsibility does not end at departure. Arrival must be proved, the movement closed and discrepancies addressed.
Confirm that sender, recipient and premises are within the licensed route.
First obtain the receiving licensee's prior consent, then apply for a movement permit stating goods type, quantity, tax due if released in transit, origin, destination, means of transport and expected duration (Regulations Art. 25).
Do not start movement before authorisation; keep the permit with the consignment. The application is decided within 7 days with silence deemed refusal, and the permit runs 15 days, extendable (Art. 26 and 27). Exception: movement between two warehouses of the same licensee needs no permit where an automated tracking system exists and a monthly report is filed within 15 days of month-end (Art. 30).
Match received and dispatched quantities and record any discrepancy immediately.
Prove arrival and close the permit; the sender's responsibility does not end when the truck departs.
Valid warehouse licence and movement permit
Stock ledger linking receipts, dispatches and balance
Transport, receipt and movement-closure evidence
Customs declaration or return and proof of tax payment
This is a concise practical list, not an exhaustive document schedule. More evidence may be needed depending on the goods, parties, guarantee and customs movement.
Production outside licensed premises is not an alternative route. Registration and licensing must be corrected immediately while addressing tax and filing; non-compliance does not remove liability.
Suspension can continue only where customs, movement-permit, guarantee and arrival-proof requirements are met. A warehouse address on an invoice is not enough.
If the shortage is loss or damage under suspension: notify NBR immediately on discovery and complete the prescribed form on the day after notice, with the warehouse licence number, reasons and documentary evidence (Regulations Art. 5(5)). If the form is late or the evidence is rejected, the goods are treated as released from the time of loss; if the Ministry does not notify its decision within 30 days of the form, the loss is deemed beyond your control. Liability may extend to the persons identified by Law and Regulations.
This guide connects Articles 4–7 and 14–15 of the Law with Articles 5–7, 14–16, 24–35 and 46 of the Executive Regulations, while requiring reference to NBR and Customs procedures for each actual movement.