Postponed Import VAT: UK PVA, Article 23, ET 14.000, Autoliquidation
Import VAT is normally paid to customs when goods are cleared and recovered weeks later through the VAT return, which ties up cash. Several European countries let VAT-registered importers declare it on the VAT return instead: the United Kingdom and Ireland through postponed accounting, France automatically through autoliquidation since 2022, the Netherlands with an Article 23 permit, Belgium with an ET 14.000 licence, Spain for importers that opt in, and Sweden and Finland for every VAT-registered importer, Austria books it on the importer's tax account, Portugal lets qualifying importers on the monthly regime opt to pay it in the VAT return, and Poland allows it for active VAT taxpayers using a customs representative or holding AEO status. Germany has no such shift, but importers with a deferment account pay import VAT later. Each scheme needs a local VAT number, so an exporter selling DDP has to register there first.
Checked against official sources: 2026-10
At a glance
Why postponing import VAT matters
Import VAT is charged on top of duty at the rate of the importing country, and a VAT-registered business can normally deduct it as input tax. Paid at the border, it is a cash-flow cost: on goods worth EUR 100,000 at a 21% rate the importer advances EUR 21,000 until its next VAT return. When import VAT is instead declared on the VAT return, a business entitled to full deduction normally declares and deducts it in the same return, so no cash leaves the business at import. Customs duty is not affected and is still paid when the goods are cleared.
Every scheme below is for businesses registered for VAT in the country of import. A buyer that imports on DAP or FCA terms uses its own registration; an exporter that sells DDP and acts as importer must first register for VAT there, or use the routes the country offers to non-resident businesses, and take local VAT advice.
Country by country
The rules and names differ, so check the scheme of the country where the goods are declared for import:
- United Kingdom: postponed VAT accounting lets a VAT-registered importer account for import VAT on its VAT return instead of paying it at the border. A non-UK business registered for UK VAT can use it by instructing its customs agent in writing and being entered as consignee.
- France: since 1 January 2022, autoliquidation of import VAT has been compulsory and automatic for businesses identified for VAT in France. The French intra-community VAT number must be on the import declaration, and the import VAT is declared on the CA3 return, which is pre-filled with the amounts.
- Netherlands: a business that imports goods from outside the EU frequently can apply to the Dutch Tax Administration (Belastingdienst) for an Article 23 permit and then declares the import VAT in its VAT return instead of paying it to Dutch Customs.
- Belgium: the ET 14.000 licence shifts payment of import VAT to the periodic VAT return, so the importer does not pre-finance VAT at customs. The Belgian tax authority provides application forms for individual taxpayers and for global fiscal representatives.
- Spain: an importer that opts for deferral, by a census declaration to the tax agency (AEAT) during November of the year before, enters the import VAT in box 77 of its modelo 303 VAT return for the period in which the import assessment is notified.
- Germany: import VAT is paid to customs and deducted as input tax with the import documents and customs proof of payment. Since 1 December 2020, importers with a customs deferment account (Aufschubkonto) have paid it only on the 26th of the second month after import, which narrows the gap before the deduction.
- Ireland: since 1 January 2021, postponed accounting lets VAT-registered importers self-account for import VAT on the VAT3 return, with the value of the goods in box PA1 and the VAT at T1 and T2; Revenue can exclude a business that does not meet the conditions by notice.
- Sweden: an importer registered for Swedish VAT reports and pays import VAT to the Swedish Tax Agency (Skatteverket) in its VAT return for the period in which Swedish Customs issued the customs invoice or receipt, and deducts it there; an importer that is not registered for Swedish VAT pays the import VAT to Swedish Customs.
- Finland: since 1 January 2018, an importer that is VAT-registered when the import declaration is approved and imports for business purposes reports the import VAT to the Finnish Tax Administration (Vero) in its periodic VAT return and deducts it there; private individuals and unregistered companies pay Finnish Customs.
- Austria: an entrepreneur registered for Austrian VAT that imports goods for its business can declare in the customs declaration that the import VAT is to be booked on its tax account at the tax office instead of being collected by customs (section 26(3)(2) UStG 1994); it falls due on the 15th of the month after booking, at the earliest the 15th of the second month after the VAT period.
- Portugal: a taxable person on the monthly VAT regime with a regular tax situation and only taxable or deductible operations can opt, on the Portal das Finanças by the 15th of the previous month, to pay import VAT in its periodic VAT return instead of at customs (article 27(8) of the VAT Code); since 1 March 2018 the option covers all goods, and it must be kept for at least six months.
- Poland: under article 33a of the VAT Act, an active VAT taxpayer can settle import VAT in its VAT return instead of paying it at customs if its customs declarations are made through a direct or indirect customs representative, or without one if it holds AEO status or a customs simplification authorisation; it first submits confirmation of its VAT registration and of no tax arrears to the head of the competent customs and tax office.
Consumer parcels: IOSS instead of import VAT
For distance sales to EU consumers in consignments up to EUR 150, the Import One-Stop Shop (IOSS) lets the seller charge EU VAT at checkout; the import is then VAT-exempt and the customer pays nothing at delivery. Customs duty still applies, including the EUR 3 per item on these distance sales from 1 July 2026 to 1 July 2028. The United Kingdom has its own rule: on consignments of £135 or less the seller or marketplace charges UK VAT at the point of sale (see Triplicate's guide to exporting to the EU and the comparison of import duty and VAT by country).
Step by step
- Find out who will be the importer: the buyer on DAP or FCA terms, or you on DDP terms.
- If you will be the importer, register for VAT in the country of import and take local VAT advice.
- Check the country's scheme: UK postponed VAT accounting, French autoliquidation, a Dutch Article 23 permit, a Belgian ET 14.000 licence, Spanish deferral, or a German deferment account.
- Apply in time where an application is needed: the Spanish option is made in November for the following year.
- Give the VAT number and any permit or licence details to the customs broker so that they appear on the import declaration.
Documents you usually need
- VAT registration in the country of import
- Article 23 permit, ET 14.000 licence or Spanish deferral option, where required
- Written instruction to the customs agent, for UK postponed VAT accounting by a non-UK business
- Import declaration showing the importer's VAT number
- Commercial invoice and packing list for the import declaration
Common problems and how to avoid them
What to do: Autoliquidation needs the French intra-community VAT number on the import declaration; make sure the broker enters it.
What to do: The deferral option is made during November for the following year; until it applies, the VAT is paid at import.
What to do: Register for VAT there or quote DAP so the buyer imports; without a local VAT number none of these schemes can be used.
What to do: It must be registered for UK VAT, instruct its customs agent in writing and be entered as consignee on the declaration.
Sources
- Check when you can account for import VAT on your VAT Return GOV.UK (HM Revenue & Customs)
- Bénéficier automatiquement de l'autoliquidation de la TVA à l'import Direction générale des douanes et droits indirects (French Customs)
- Importing products from a non-EU country Business.gov.nl (Netherlands Enterprise Agency)
- These are the VAT rules when trading with the UK Netherlands Chamber of Commerce (KVK)
- License ET 14000: shifting VAT to the periodic VAT return FPS Finance, Belgium
- IVA a la importación, cómo diferir su pago Agencia Tributaria (AEAT)
- Aufschubkonten für die Einfuhrumsatzsteuer IHK Magdeburg (Chamber of Industry and Commerce)
- Value-added Tax Germany Trade & Invest (GTAI)
- Explanatory notes on VAT e-commerce rules (IOSS, deemed supplier, intrinsic value) European Commission, DG TAXUD
- Guidance and legal text on temporary flat fee on low-value imports which will apply until 1 July 2028 European Commission, DG TAXUD
- Postponed Accounting (Tax and Duty Manual, Part 07) Revenue (Irish Tax and Customs)
- Purchasing goods from non-EU countries Swedish Tax Agency (Skatteverket)
- Value added taxation of imported goods Finnish Tax Administration (Vero)
- § 26 UStG 1994 Sondervorschriften für die Einfuhrumsatzsteuer JUSLINE Österreich
- Ofício Circulado n.º 30193/2017, de 11 de agosto (IVA nas importações) Autoridade Tributária e Aduaneira, via Informador Fiscal
- Zmiany w zakresie rozliczania podatku VAT z tytułu importu towarów bezpośrednio w deklaracji podatkowej Ministry of Finance, Poland (podatki.gov.pl)
Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.
Trade notes
Common questions
What is postponed import VAT?
Declaring import VAT on the VAT return instead of paying it to customs at the border. A business that can deduct the VAT in full declares and deducts it in the same return, so no cash is advanced.
Which EU countries let importers declare import VAT in the VAT return?
Among others, France (automatic autoliquidation), Ireland (postponed accounting), Sweden and Finland (every VAT-registered importer), Austria (tax account booking), Portugal (option for monthly filers), Poland (article 33a), the Netherlands (Article 23 permit), Belgium (ET 14.000 licence) and Spain (deferral by opting in). Germany does not, but its deferment account holders pay later.
What is the Article 23 permit in the Netherlands?
A permit from the Dutch Tax Administration that lets a frequent importer declare import VAT in its VAT return instead of paying it to Dutch Customs at import.
Can a non-resident business use postponed VAT accounting?
Only with a VAT registration in the country of import. In the UK, a non-UK business registered for UK VAT instructs its agent in writing and is entered as consignee; in Belgium, global fiscal representatives can apply for the ET 14.000 licence.
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