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Practical Handbook VAT 2021


Non-customs warehousing procedure

With effect from 11 July 2021, Article 8.Three of Law 11/2021, of 9 July, extends the case of subsidiary liability for payment of the tax debt that reaches whoever holds the ownership of warehouses other than customs warehouses corresponding to the exit or abandonment of goods from these warehouses, to goods subject to Excise Duties, excluded to date to prevent the benefits of the regime from being used fraudulently to make purchases exempt from VAT under the regime, with accrual of the Tax on exit, but without payment of the same to the Public Treasury.

However, in the case of products subject to taxes on alcohol and derived beverages or hydrocarbons, this liability shall not be demanded of the person who holds the ownership of the warehouse when the departure or abandonment of the goods has been carried out by a person or entity authorised for this purpose and recorded in the register of extractors of these products, an administrative register where these persons or entities must be registered, which is created for this purpose.

Customs agents

With effect from 11 July 2021, Article 8.1 of Law 11/2021 of 9 July updates the case of subsidiary liability for payment of the tax, currently defined for customs agents, which will apply to persons or entities acting in the name and on behalf of the importer.This brings the provision into line with the changes in the field of customs representation and the customs representative.