Members should already be aware that a consultation on red diesel is being conducted by HMRC as they have been directed to respond to the EU assertion that boaters should be paying full rates of duty on diesel. HMRC have clearly stated that they require responses from individuals rather than representative organisations. RBOA therefore encourages all members to submit their own response before the closing time of 11.45 p.m. on 9th September 2019.
The HMRC consultation documents can be found at:
The key questions for those living afloat are in paragraph 5.6 – numbers 9 – 19, particularly numbers 14, 16, 17 and 19, which ask about the possible problems of refuelling with red or white diesel, the avaulability of the fuel, and the option to have an additional tank constructed for white diesel.
The following points may help with your responses:
* The majority of boats on inland waterways only have one diesel tank to serve both propulsion and domestic requirements.
The addition of a second fuel tank would, in many cases, be impractical because of lack of space.
* The cost of adding a second tank, where possible, would be £500 according to HMRC though this appears to exclude the installation, pressure testing, certification etc.
* Installation of additional fuel tanks could seriously affect the stability, and therefore safety, of boats that were designed for just one tank.
* Running the engine to generate electricity and hot water could mean that propulsion duty would be charged on these basic essentials unless the engine could be switched between domestic and propulsion tanks. This arrangement still leaves the possibility of using the engine for propulsion from the domestic fuel tank.
* The expense of an additional fuel tank could lead to inappropriate installations with resultant safety and environmental risks.
* Where it is impossible to add a second fuel tank, boat dwellers would be discriminated against by being charged duty on domestic fuel when house dwellers do not incur this tax.
* Boats with one fuel tank would take a very long time to purge their fuel system of red dye, thus making new regulations unenforceable for some time.
* The need for marine diesel suppliers to install additional pumps and storage tanks for provision of both red and white diesel would be uneconomic, leading to a dramatic reduction in the availability of waterside fuel suppliers.
* The high cost to boat owners, fuel suppliers and the Government would result in a minute increase in tax revenue.
It appears that residential boat owners whose primary or only residence is their boat at fixed mooringsand only move occasionally will continue to be able to purchase red diesel at the lower duty rate for all pirposes by ptoviding documentation such as a Residential Mooring Licence, council tax bill for the mooring, or other documentation showing permanent residence. This continues the current practice in Excise Note 554 – Article 4.7.
HMRC has stated that responses must be from individuals, not from organisations, which means that RBOA cannot make a response to this consultation on your behalf. We would usrge all members to submit a response to gary.satchell@hmrc.gov.uk
It would be helpful if yu could copy your response to Vice Chairman, Rex Walden, who is collecting responses to inform RBOA’s response to any future requests for information on this matter. His email is: rex.walden@live.co.uk