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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

United KingdomPostponed VAT accounting: VAT-registered importers account for import VAT on the VAT return
FranceAutoliquidation, automatic since 1 January 2022 with a French VAT number on the declaration; CA3 return
NetherlandsArticle 23 permit from the Dutch Tax Administration for frequent importers
BelgiumET 14.000 licence shifts import VAT to the periodic VAT return
SpainDeferral by opting in during November for the next year; box 77 of modelo 303
GermanyNo shift to the VAT return; deferment account holders pay on the 26th of the second following month
EU consumer parcelsIOSS: VAT charged at checkout on consignments up to EUR 150, no import VAT at the border
IrelandPostponed accounting since 1 January 2021: import VAT on the VAT3 return
SwedenVAT-registered importers report import VAT to Skatteverket in the VAT return; others pay Swedish Customs
FinlandSince 1 January 2018, VAT-registered importers report import VAT to the Tax Administration in the VAT return
AustriaImport VAT booked on the tax account if declared in the customs declaration (section 26(3) UStG)
PortugalOption to pay import VAT in the periodic VAT return (article 27(8) CIVA), all goods since 1 March 2018
PolandArticle 33a VAT Act: import VAT in the VAT return for active VAT taxpayers with a customs representative or AEO status

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:

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

  1. Find out who will be the importer: the buyer on DAP or FCA terms, or you on DDP terms.
  2. If you will be the importer, register for VAT in the country of import and take local VAT advice.
  3. 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.
  4. Apply in time where an application is needed: the Spanish option is made in November for the following year.
  5. 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

Common problems and how to avoid them

Import VAT was charged at the French border although the importer is VAT-registered in France.

What to do: Autoliquidation needs the French intra-community VAT number on the import declaration; make sure the broker enters it.

A Spanish importer wants to stop paying import VAT at clearance in the middle of the year.

What to do: The deferral option is made during November for the following year; until it applies, the VAT is paid at import.

An exporter quotes DDP to Europe without a VAT registration in the country of 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.

A non-UK business cannot use postponed VAT accounting on its UK imports.

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

  1. Check when you can account for import VAT on your VAT Return GOV.UK (HM Revenue & Customs)
  2. Bénéficier automatiquement de l'autoliquidation de la TVA à l'import Direction générale des douanes et droits indirects (French Customs)
  3. Importing products from a non-EU country Business.gov.nl (Netherlands Enterprise Agency)
  4. These are the VAT rules when trading with the UK Netherlands Chamber of Commerce (KVK)
  5. License ET 14000: shifting VAT to the periodic VAT return FPS Finance, Belgium
  6. IVA a la importación, cómo diferir su pago Agencia Tributaria (AEAT)
  7. Aufschubkonten für die Einfuhrumsatzsteuer IHK Magdeburg (Chamber of Industry and Commerce)
  8. Value-added Tax Germany Trade & Invest (GTAI)
  9. Explanatory notes on VAT e-commerce rules (IOSS, deemed supplier, intrinsic value) European Commission, DG TAXUD
  10. Guidance and legal text on temporary flat fee on low-value imports which will apply until 1 July 2028 European Commission, DG TAXUD
  11. Postponed Accounting (Tax and Duty Manual, Part 07) Revenue (Irish Tax and Customs)
  12. Purchasing goods from non-EU countries Swedish Tax Agency (Skatteverket)
  13. Value added taxation of imported goods Finnish Tax Administration (Vero)
  14. § 26 UStG 1994 Sondervorschriften für die Einfuhrumsatzsteuer JUSLINE Österreich
  15. Ofício Circulado n.º 30193/2017, de 11 de agosto (IVA nas importações) Autoridade Tributária e Aduaneira, via Informador Fiscal
  16. 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.

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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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