How do duty payments work when operating a brewery and distillery on the same site, particularly when producing duty-suspended whisky spirit?
When operating a brewery and distillery together, the key is maintaining clear separation and documentation. Members operating multi-site or multi-purpose facilities report that HMRC compliance requires: clear designation of areas on your site plans separating brewery from distillery operations; meticulous records distinguishing duty-suspended stock from duty-paid stock; and separate accounting for each operation.
Members' practical experience: - **Designated warehouse areas** — Ensure your site plans clearly identify separate zones for beer production (duty-paid) and spirit production (duty-suspended). This prevents confusion with HMRC about which product is subject to which duty regime. - **Duty-suspended spirit sales** — Members are successfully selling whisky spirit duty-suspended to third-party partners who store it in warehouses under their WOWGR (Warehouse and Other Goods Regulations), without this affecting the duty calculations on concurrent beer production. The key is that duty suspension and duty-paid operations are treated independently if areas and records are properly designated. - **Meticulous stock records** — Maintain detailed records of what is held duty-suspended versus duty-paid. This documentation is critical for HMRC audits and compliance.
**Caveat:** HMRC's guidance on this scenario is unclear and sometimes contradictory. One member noted that HMRC themselves "don't seem able to give a straight answer" on the implications. Get written confirmation from your local HMRC office on your specific site layout and product mix before scaling production.
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