Import VAT in the return, not at the border
Which EU countries let importers declare import VAT in the VAT return instead of paying it at the border, on what conditions, and why it helps cash flow.
Several EU countries let a VAT-registered importer declare import VAT in its periodic VAT return instead of paying it in cash to customs when the goods are released. For a business with a full right to deduct, the same VAT is declared and deducted through the return, so the import itself takes no VAT cash out of the business. Portugal offers this as an option under article 27.º n.º 8 of its VAT Code. The Netherlands, France, Spain, Ireland and Sweden each have their own version, under their own names and conditions.
The trade calls it postponed accounting, reverse-charge import VAT, or self-assessment of import VAT. The label varies by country. The cash effect is the same idea everywhere.
What does postponed import VAT accounting mean?
When goods from outside the EU are released for free circulation, import VAT falls due in the country of import. The default route is simple: customs calculates it, and the importer pays it before the goods move. The importer then deducts that VAT in a later VAT return, subject to its right to deduct.
Postponed accounting changes only the payment route. The EU VAT Directive leaves member states to set the payment rules for imports. Its Article 211 then allows them to provide that import VAT is not paid at the time of importation, provided it is entered in the VAT return. Each country decides whether to use that permission, for whom, and on what conditions.
The duty is a separate matter. Customs duty is not VAT. It is owed on release and is not moved into the VAT return.
Why does it matter for cash flow?
Suppose a maker of kitchen appliances from outside the EU releases one container into free circulation in Portugal. The figures below are hypothetical, for the mechanics only. The customs value is 200,000 euros and, for the example, the duty rate is 4 percent. Under Article 86 of the VAT Directive, the import VAT base includes the duty. Portugal’s standard VAT rate on the mainland is 23 percent.
| Line | Paid to customs at release | Import VAT in the Portuguese return |
|---|---|---|
| Customs duty, 4 percent of 200,000 | 8,000 euros | Not in the return: 8,000 euros paid to customs at release |
| Import VAT, 23 percent of 208,000 | 47,840 euros | 47,840 euros declared |
| Same VAT, deducted | in a later return | 47,840 euros deducted |
| VAT cash out on the import | 47,840 euros, until the deduction comes back | 0 euros, with a full right to deduct |
On the first route, 47,840 euros leaves the business on release day. It returns only as a deduction in the VAT return for that period. A Portuguese monthly return is due by the 20th day of the second month after the month it covers. So VAT paid on 5 March is deducted in the March return, which is due by 20 May. Where the deduction exceeds the VAT on sales, it becomes a credit, recovered on the tax authority’s timetable.
On the second route, no VAT cash moves on the import. The duty of 8,000 euros is owed to customs either way.
Multiply that by a container every month and the difference stops being an accounting detail. Import VAT paid at the border is working capital lent to the state for weeks at a time. For a business that imports steadily, that loan never closes.
How does Portugal’s option work?
Article 27.º n.º 8 of the Código do IVA lets a business opt to account for the VAT on its imports in its periodic return. Three conditions apply. The business must be in the monthly return regime. Its tax position must be regularised. And it must carry out only taxed operations, or exempt operations that give a right to deduct. A fourth condition was revoked. The form and timing of the option are set by ministerial order, under n.º 9 of the same article.
The monthly regime is the first gate. Under article 41.º of the Código do IVA, businesses with a turnover of 650,000 euros or more in the previous calendar year file monthly. Businesses below that file quarterly, but may opt into the monthly regime. For an already registered business, that option is exercised in January, with effect from 1 January. A new business can make that option in its declaration of start of activity (article 41.º n.º 3).
Where the conditions are not met, import VAT is paid to customs on release in the ordinary way. A business from outside the EU reaches the Portuguese VAT register through a fiscal representative, as set out in who needs a fiscal representative in Portugal.
Which other EU countries offer it?
Each of the countries below appears here because its tax or customs authority says so on an official page opened for this article. Other member states may have similar rules; they are left out rather than guessed.
Netherlands. Import VAT is paid to customs by default. Under conditions, it can instead be declared in the VAT return, under what the Belastingdienst calls the reverse-charge arrangement for imports from non-EU countries. This needs an article 23 licence. A foreign business cannot apply for that licence itself. It can use a fiscal representative, who can apply the arrangement for it, so that no VAT is paid to customs on the import declaration.
France. Since 1 January 2022, self-assessment of import VAT is automatic and mandatory for every business identified for VAT in France, with no prior authorisation. The VAT is declared on the French VAT return. French customs states that foreign companies, from the EU or outside it, that clear goods for import in France must hold a valid French VAT number.
Spain. The Agencia Tributaria calls it deferral of import VAT. The option is chosen through a census declaration filed in November, before the calendar year in which it takes effect. Once chosen, it applies to all imports made in that year, and it renews for the following years unless it is renounced or the business is excluded. The import VAT is declared in box 77 of form 303. Assessed amounts not included in the return go straight to enforced collection.
Ireland. Revenue offers postponed accounting to all traders registered for VAT and for Customs and Excise, on imports from third countries including Great Britain, excluding Northern Ireland. It is optional. The VAT is declared on the VAT3 return and can be reclaimed at the same time, subject to the usual rules on deductibility. Traders must meet conditions and show compliance when Revenue asks.
Sweden. A VAT-registered importer reports and pays import VAT to the Swedish Tax Agency through its VAT return, not to customs. The VAT is reported for the period in which customs issued its bill or receipt. A business that is not VAT-registered in Sweden declares and pays the import VAT to Swedish Customs instead.
What does postponed accounting not change?
It does not remove customs duty. Customs duty is owed on release, on every route; it is not moved into the VAT return.
It does not make VAT disappear. The VAT is declared. It nets to zero only where the business can deduct it in full; Ireland’s Revenue says so plainly, making the reclaim “subject to the usual rules on deductibility”. A business with exempt activity carries part of it as a cost.
It does not forgive a missed filing. The zero depends on a correct return filed on time. Spain’s rule on unreported amounts shows how quickly a slip becomes a debt.
It does not settle the VAT on sales. What the business charges its customers, in Portugal, to businesses in other EU countries, or to consumers through the One Stop Shop, is a separate set of obligations.
And it is no substitute for advice on a specific business. This is general information, not legal or tax advice. Whether a business qualifies is decided by the rules of each country and, where needed, by its tax authority.
How this runs at EFC
For goods released at EFC’s base in Portugal, run with its logistics partner, import VAT goes in the Portuguese VAT return rather than to customs in cash where the conditions of article 27.º n.º 8 are met. That sits alongside fiscal representation in Portugal, and is confirmed with the client’s tax adviser. EFC does not give legal or tax advice.
The same option works when goods land at another EU port and travel to Portugal in T1 transit, because the release, and the import VAT, then happen in Portugal. The release itself is explained on release for free circulation. Where the stock is sold on to VAT-registered business buyers in other member states, the import can instead be set up so that no import VAT is paid in Portugal. EFC structures that case by case, for business sales only, as set out on selling to businesses.
Sources
| Label | Value | Source |
|---|---|---|
| EU basis | member states may provide that import VAT is not paid at importation, provided it is entered in the VAT return | Directive 2006/112/EC, Article 211, EU text on legislation.gov.uk, opened 2026-07-30 |
| Import VAT base | includes duties due by reason of importation, excluding the VAT itself | Directive 2006/112/EC, Article 86, EU text on legislation.gov.uk, opened 2026-07-30 |
| Portugal, the option | monthly regime; regularised tax position; taxed operations or exempt with a right to deduct; condition d) revoked; form set by portaria | Código do IVA, artigo 27.º n.º 8 and 9, Portal das Finanças, opened 2026-07-30 |
| Portugal, standard rate | 23 percent | Código do IVA, artigo 18.º, Portal das Finanças, opened 2026-07-30 |
| Portugal, monthly regime | 650,000 euros turnover threshold; monthly return due by the 20th of the second following month; option exercised in January | Código do IVA, artigo 41.º, Portal das Finanças, opened 2026-07-30 |
| Portugal, authority page | functionality for taxpayers who exercised the article 27.º n.º 8 option | Autoridade Tributária, IVA na Importação de Bens, opened 2026-07-30 |
| Netherlands | article 23 licence; foreign business cannot apply itself; fiscal representative can apply the arrangement | Belastingdienst, importing from non-EU countries, opened 2026-07-30 |
| France | since 1 January 2022, automatic and mandatory for businesses identified for VAT in France; foreign companies need a valid French VAT number | French customs, self-assessment of import VAT from 1 January 2022, opened 2026-07-30 |
| Spain | census declaration in November; applies to all imports in the year; renews unless renounced or excluded; box 77 of form 303; unreported amounts to enforced collection | Agencia Tributaria, IVA a la importación, cómo diferir su pago, opened 2026-07-30 |
| Ireland | all traders registered for VAT and Customs and Excise; optional; VAT3 return; reclaim subject to deductibility | Revenue, Postponed accounting, opened 2026-07-30 |
| Sweden | VAT-registered importers report import VAT to the Tax Agency; others pay Swedish Customs | Skatteverket, buying goods from outside the EU, opened 2026-07-30 |