File an EU VAT Recapitulative Statement to give details on your sales to EU countries
You must complete a recapitulative statement to report your selling to customers in other EU countries. In addition, you must complete a VAT return by the deadlines that depend on your tax period.
The requirement to file a recapitulative statement is part of the VAT control system within the EU that monitors commercial operations with goods and services.
The statement must be filed
- When you have sold goods, i.e. carried out an intra-Community supply, and transferred your own goods in such a way that it is treatable as an intra-Community supply
- When you have been the second seller in a triangulation scheme
- When you have sold services in a VAT scheme where the buyer must pay VAT in another EU country
Note: As of 1 January 2020, the transfer of goods following the call-off stock procedure can no longer be considered comparable to sales of goods in the country where the goods are transferred from. If you are a seller that transfers goods to call-off stocks, you must submit a report to inform the Tax Administration of the transfers.
Do not report the intra-Community sale on a VAT return until after the change of ownership. Report the sale as before on the VAT return and on the recapitulative statement.
When and how must the statement be filed?
The VAT EU recapitulative statement must be filed each month no later than on the 20th of the calendar month after the month of the taxable transaction. For example, if you sold something to EU customers in September, you must file the statement by 20 October. If the 20th falls on a Saturday, Sunday or a public holiday, the due date is extended to the next business day.
You are only expected to file a statement for a month when you actually sold goods, or rendered some services, to a customer in another EU country.
You must provide a specification for every customer, indicating the total sales volume to each one, and also fill in their VAT numbers.
You can file the VAT recapitulative statement on paper only if there is a special reason: for example, if electronic filing is impossible due to technical difficulties.
What happens if I file the statement after the date when it is due?
If you are late in filing the recapitulative statement or if you fail to file it, you may have to pay a punitive charge for negligence. The size of the neglicence penalty varies between €100 and €200, depending on how many days you are late.
How should I account for my sales month-for-month?
If an intra-Community supply of goods takes place, it should be reported during the month that comes after the month of delivery of goods.
However, if the buyer has been given an invoice or similar document during the month of delivery, the intra-Community supply should be reported during that month instead.
However, if the invoice is only for an advance payment, it should be reported during the month that comes after the month of delivery.
Example: Goods are delivered to another EU country in March. The seller sends the invoice in April. For purposes of monthly accounting, the right period to report this intra-Community supply is April: it should show on the seller’s recapitulative statement filed for April.
Example: Goods are delivered to another EU country in March. The seller sends the invoice in March. The period to report this intra-Community supply is March: it should show on the statement filed for March.
If an intra-Community supply of services takes place, it should usually be reported during the month when the services are actually being rendered or provided. However, if payment or part of it is made before the month when services are rendered, the obligation to pay VAT will arise during that month instead.
Example: The seller renders a service to a service recipient in another EU country, and the buyer pays the invoice in March. This intra-Community supply must be reported for March: it should show on the statement that the seller of services files for March.
Example: The seller renders a service to a service recipient in another EU country in March, and the buyer pays the invoice in April. This intra-Community supply must be reported for March: it should show on the statement that the seller of services files for March.
Some types of services involve a continuous process of rendering services to the buyer, and special VAT rules will apply. It is typical for continuous services that the payment is largely based on the time elapsed, as in the case of renting out an asset of some kind. If a continuous service is rendered, the right month to report it is the end month of each payment period.
Example: If there is a leasing agreement that specifies three-month intervals of paying rent, the period to report it is the third month, i.e. the month when rent is paid. If a prepayment is made in advance of the third month of the three-month period, it must be reported the month when the prepayment is paid.
However, if the payment is being made in several installments, it does not mean that the service is a continuous service. Similarly, if the payment is based on a measured amount of rendered services, instead of being based on the passing of time, the service is not a continuous service. This means that a contract to erect a building, for example, does not involve a continuous delivery of goods or services.
If a continuous service is agreed as going on longer than a year but no invoicing or payment has taken place during a relevant period, the supply of services is treated as completed at the end of each calendar year up to the time when the contract terminates. Supply of the services must always be reported on the VAT EU recapitulative statement for December. For a supply carried out after the calendar year has ended, the month to file the statement is the month when services were rendered for the final time.
For goods as well as for services, any sales-related annual discounts and exchange discounts, sales rebates, surplus reimbursements or credits etc. must be reported for the same month as when they are entered in accounting.
If you file a statement and notice that it contained and error – such as a wrong VAT number or a wrong sales total – you should file a replacement report in MyTax, filling in the replacement amount in the customer-specific fields. This new statement replaces the one earlier you had filed previously. There is no need to repeat the lines where specific reporting on other customers has been correct.