Import Traders and Logistics Companies

How do businesses invoice goods held in customs warehouses?

Goods held in customs warehouses are suspended from VAT and customs duties until they leave the warehouse. No VAT is charged on transfers of goods within the customs warehouse regime. When goods are released for free circulation (exit the warehouse into the domestic market), import VAT and customs duties become due at that point. Invoices for goods within the warehouse must clearly indicate the customs warehouse status to avoid premature VAT charging.

How does the customs warehouse regime affect invoicing?

Customs warehouse invoicing requires specific notations and suspended VAT treatment:

  • Warehouse entry: Goods enter under customs warehouse procedure; import VAT suspended
  • Transfer within warehouse: Sale of goods while in customs warehouse; no VAT; invoice notes 'customs warehouse' status
  • Regime reference: Customs warehouse authorization number included on invoices for goods in regime
  • Release to free circulation: Import VAT and duty due when goods leave warehouse for domestic market
  • VAT invoice on release: Full VAT invoice issued when goods exit customs warehouse into free circulation
  • Compliance risk: Incorrectly charging VAT on warehouse transfers or not charging on releases can trigger customs and VAT investigations

Frequently Asked Questions

What are the advantages of using customs warehouses for VAT cash flow?
Customs warehouses allow importers to store goods without paying import VAT or duties until the goods are actually needed for sale. This provides significant cash flow benefit for importers holding large inventories: a business holding EUR 5 million in goods in a customs warehouse defers EUR 1 million (at 20 percent VAT) in import VAT until each batch of goods is released. For seasonal goods or goods held speculatively, the deferral benefit can be substantial.
How do customs warehouses interact with postponed VAT accounting?
Postponed VAT accounting (PVA) and customs warehouses are different regimes that can both defer import VAT but in different ways. PVA defers import VAT to the VAT return without cash payment at the border; the goods are imported into free circulation. Customs warehouses suspend import VAT entirely while goods remain in the warehouse; VAT only becomes payable when goods leave the warehouse. Businesses can choose which regime is more advantageous based on how long they hold goods before sale.

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