The EU VAT Quick Fixes coming into force on 1 January 2020, it is still time for businesses to assess their situation and review their processes in place for EU B2B intra-Community supplies
What are the changes?
As you are aware of, the EU Commission adopted four Quick Fixes to simplify and harmonise the current VAT system for B2B intra-Community supplies of goods and address particular pain points in that respect.
The Quick Fixes are:
- Simplification for call-of stock supplies: uniform simplification where a supplier transfers own goods to a stock at the disposal of a known customer in another Member State based on a call-off stock arrangement;
- Harmonised rule to allocate the transport in a chain transaction: legal certainty regarding the allocation of transport performed by the intermediary operator in an intra-Community chain transaction;
- Mandatory requirement to obtain the VAT ID number of the customer: obtaining the valid VAT ID number of the customer will be a substantial requirement to benefit from the VAT exemption for intra-Community supplies;
- Reduced set of documents to prove the transport of goods in case of intra-Community supplies: presumption of intra-Community transport when the set of document is provided.
The Commission published a draft explanatory note in September 2019, which provides practical examples and useful guidelines / Q&A to deal with the Quick Fixes, although not binding for the Member States. Member States have until the end of 2019 to implement the Quick Fixes in their local legislations. Hence, some deviations can be expected. Based on our last information, several Member States have already published local guidelines (e.g. Austria, Belgium, Croatia, Finland and Germany) while others have only drafts under discussion (e.g. Bulgaria, France, Spain and Sweden) or nothing yet (e.g. Greece, Italy and UK).
Actions for businesses
Although not all Member States have implemented the Quick Fixes yet and some uncertainties remain, businesses must review their current flows to identify potential impacts/opportunities/simplifications and, where needed, adapt their ERP system in case of a major change of the supply chain resulting from these Quick Fixes.
If you would like to discuss more on this topic, please do reach out to our key contacts below.
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