As an EU composed of 27 member states, the goods of member states can flow freely and do not need to be cleared twice. In order to facilitate the statistics on the flow of goods of each member state, the Intrastat system was established to count the inbound and outbound transaction data of goods of each member state.
For goods trading in the European Union, in addition to the VAT registration and VAT declaration in the countries where the goods are stored, there is Intrastat declaration, another important type of declaration, which is different from VAT declaration. Generally speaking, when I do B2B intrastat declaration within the European Union, because it is not part of the VAT declaration form, the tax agency of some countries needs to charge extra.
What is INTRASTAT?
INTRASTAT is the statistical system used to collect information on trade in goods within the European Union. Businesses use INTRASTAT reports to record all cross-border B2B transactions within the European Union.
In Italy, for example, INTRASTAT declaration includes IT to EU, which is Italy's cross-border B2B sales declaration, also known as EC Sale listing. Meanwhile, INTRASTAT declaration also includes EU to IT, that is, Italy's cross-border B2B procurement declaration, also known as FC Transfer listing.
Usually Intrastat declarations are administered by the customs or statistical authorities of the EU Member States.
Do I need to submit the Intrastat declaration?
Each EU Member State has an annual Intrastat declaration threshold, and the threshold for the amount of money to enter and leave the country will be different for the same member State. Taking the Intrastat threshold in the European Union, which is common for our Amazon buyers, as an example, the threshold of each country is sorted out as follows for reference.
The threshold calculation is based on the aggregate of B2B transaction amounts in the previous four quarters, not the natural year Q1-Q4.
If the corresponding country does not exceed the corresponding threshold above, it can choose to declare; But if they exceed the corresponding threshold, they will be forced to report, otherwise they will be fined.
Do cross-border B2B transactions need to be declared?
-- Goods shipped to other EU countries from the country of declaration are subject to Intrastat sales declaration (also known as EC Sale listing) in the country of declaration. For example, B2B sales from IT to other EU countries need to be declared Intrastat in IT.
-- B2B goods sent from other EU countries to the declaring country should be subject to Intrastat procurement in the declaring country. For B2B sent to IT from other EU countries, Intrastat procurement declaration is required in IT.
My EU inbound B2B transaction has not exceeded
If the threshold is exceeded, Intrastat procurement is required
Do you declare?
Normal B2B procurement within the EU is free to choose whether or not to declare Intrastat procurement if the threshold is not exceeded. In particular, if the seller's goods are imported through customs clearance deferred, after customs clearance, the importer (usually logistics clearance company) must Intrastat the EC Sale Listing in the importing country (e.g. NL,BE,CZ). The seller must provide the relevant documents to the tax agent in the destination country for Intrastat purchase declaration.
Deferred customs clearance without Intrastat procurement
What are the consequences of a declaration?
Since import VAT is not charged in the deferred customs clearance method, the customs of the destination country will track the destination of the goods according to the VIES VAT exchange system. If the seller fails to declare Intrastat procurement, he will receive a huge fine in the destination country and need to pay the deferred import VAT. It is also possible that the goods in storage will be raided.
Amazon goods moving warehouse counting transnational B2B
A deal? Do I need to declare it?
Since the seller's VAT number of the EU countries is an independent tax number, the Transfer of goods inventory of the same seller from different countries will be regarded as B2B transaction within the EU. Therefore, strictly speaking, FC Transfer of Amazon goods needs to be declared Intrastat procurement in the destination country.
However, since the sellers' VAT agents in the EU countries may not all perform Intrastat declaration, if they only perform Intrastat purchase declaration in a certain destination country and no corresponding Intrastat sales declaration is made in other delivery countries, the Intrastat entry and exit data of the corresponding countries in the EU will not match. Will cause even bigger problems.
Considering that the goods transferred by FC Transfer are declared in the corresponding countries using the seller's own EU tax number, if the intrastat declaration is done for the FC transfer data in one country, the corresponding data should also be declared for the goods transferred between this country and another country. For example, the FC Transfer data of the seller has been intrastat declared for the transfer of goods between IT and DE (including the EC sale listing declaration of IT-DE and the procurement declaration of DE-IT). Then the seller also needs to make the corresponding intrastat declaration with IT at DE (including the declaration of IT-DE procurement and the declaration of DE-IT EC sale listing), and their declaration data should be consistent.
In addition, according to the analysis of the German accountant of Amb, SK of FC Transfer is the return warehouse, and generally the seller does not have SK EU tax number, and SK is not a normal warehouse of shipment. The transfer of SK to other EU warehouses does not constitute Intrastat sales declaration, and the seller cannot do EC sale listing in SK. Therefore, other EU countries do not need to do Intrastat purchase declaration from SK when receiving SK's in-warehouse goods.
However, for other normal warehouses (such as Amazon's DE, FR, IT, ES, PL, CZ), if FC Transfer occurs, the goods transferred to the destination warehouse country, if the destination warehouse country has no tax number, it will be considered as B2C cross-border sales in the EU. The tax shall be paid in the country of shipment according to the tax rate of the destination warehouse. The value of the goods transferred shall be the cost price of the goods.
To sum up, although Intrastat declaration by FC transfer does not require additional taxes for the inventory countries where the sellers have tax numbers, the goods transferred to countries without tax numbers will be considered as cross-border B2C sales that need to be taxed in the country of shipment. Once declared, intrastat declaration should also be done in the country where the goods are transferred. However, if the threshold is exceeded, there will be a fine. The complexity of FC Transfer's declaration is worth considering.