Some EU Member States, such as notably Spain, Portugal, Poland, Italy, The United Kingdom, Ireland and Belgium, have already introduced measures in regards to VAT obligations and payment aiming at reducing the financial impact of Coronavirus. Other countries may follow shortly. If your business is facing difficulties because of the current outbreak and struggles to fulfil VAT obligations, please do not hesitate in contacting us and we will check whether VAT simplification or mitigation measures are available and assist with their implementation.
Letters of intent for usual exporters
In case a business performs zero rated supplies (intra-EU supplies and exportations) in Italy for more than 10% of its annual turnover, it may obtain the status of “usual exporter”. As such, it is entitled to purchase VAT free services and goods up to the amount of the zero-rated supplies made during the previous year.
This scheme is subject to conditions, including the issuance of “letters of intent”. The Italian tax Authorities have published the new model of document, which may be found here.
The information about the letters of intent issued by usual exporters is now available online.
No more annual filing of European Sales Lists
Up now, it was possible to submit the European Sales Lists (ESL - modelo 349) on an annual basis in Spain, if conditions were met (depending on the turnover and the level of intra-EU supplies of goods).
The annual declaration period for ESL is now abolished. In 2020, modelo 349 may therefore be submitted on a monthly or quarterly basis only.
SAF-T files instead of VAT returns
As we previously announced, SAF-T files will replace the periodical VAT returns in Poland. Due to the Coronavirus crisis, it has however been decided to postpone the entry into force.
As of July 2020, this will apply to large businesses (at least 250 employees or turnover of EUR 50 million and balance sheet total above EUR 43 million). These thresholds have to be regarded from a global perspective, meaning that the foreign entities with a Polish VAT number should not consider their Polish activities only. Small and medium business will be impacted as of October 2020.
The SAF-T files will have to meet precise conditions in order to be compliant and additional information will therefore have to be included.