The implemented changes are related to the following issues:
Concerning the chain transactions, i.e. such transaction with goods where during one transport, the right to treat the goods as an owner is transferred at least twice, the transport will be assigned to the supply between:
Further, we would like to point out that the VAT exemption for the supply of goods to another EU Member State will be applied only to sales to VAT-registered customers in that EU Member State. The fulfilment of this condition will need to be properly verified through VIES system. Another condition will be to report such supplies correctly by the supplier in its European Sales List.
In this respect, we recommend to all taxpayers to verify that the customer has a VAT number assigned via VIES each time an invoice is issued to that customer. As part of the preparation of the VAT return, we also verify the validity of the VAT number. However, VIES is only able to confirm the validity of this number as of the date of the check (i.e. in our case at the date of preparation of the European Sales List). Therefore, if the VAT number was obtained / lost in the meantime between the supply of goods itself and the preparation of the European Sales List, we are unable to verify the existence and validity of the VAT number in a credible manner.
Should you have any uncertainty about the VAT application by your contracts based on the above described changes, we will be more than happy to assist you. Please do not hesitate to contact us. We are ready to prepare a review of your currently realized supplies and to point out possible tax risks.
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