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VAT practical manual 2021.


Warehousing regime other than customs

With effect from July 11, 2021, article 8.Three of Law 11/2021, of July 9, extends the assumption of subsidiary liability for the payment of the tax debt that reaches the person who holds ownership of deposits other than those customs duties corresponding to the departure or abandonment of goods from these warehouses, to goods subject to Special Taxes, excluded to date to prevent the benefits of the regime from being used fraudulently to make purchases exempt from VAT under the protection of the regime, with accrual of the Tax upon departure, but without payment of the same to the Public Treasury.

However, in the case of products subject to the Taxes on Alcohol and Derived Beverages or on Hydrocarbons, this responsibility will not be required from the person holding the ownership of the deposit when the departure or abandonment of the goods has been carried out by a person or entity. authorized for this purpose to be recorded in the registry of extractors of these products, an administrative registry where said persons or entities must be registered, which is created for said purposes.

Customs agents

With effect from July 11, 2021, article 8.One of Law 11/2021, of July 9, updates the assumption of subsidiary responsibility for the payment of the tax, currently defined for customs agents, which will apply to the persons or entities acting in the name and on behalf of the importer. In this way, the provision is aligned with the modifications established in the field of customs representation and the figure of the customs representative.