COVID19: Effects on VAT Filing and Payments in the EU

Please find here below an overview of all EU Member States and the measures they have announced until today in order to facilitate and to support businesses to overcome the COVID-19 crisis.

Austria

VAT Filing

VAT returns should be filed on time. Penalties will continue to be applied for late VAT return filing.

VAT Payment

The Austrian Tax Authorities have confirmed the possibility for all businesses to request a VAT payment deferment when a company can prove that its activities have been affected by the COVID-19 outbreak. If a company’s VAT payment deferment application is denied, the company will have a one week extension following the refusal to pay the due VAT amount.

When a company obtains approval for the VAT payment deferment, the deadline to pay any VAT due is 30th September 2020.

If no VAT deferment request has been made, penalties will be applied on any late VAT payments.

Belgium

VAT Filing

The filing deadlines for VAT and Intrastat (EC sales listing) returns in Belgium have been deferred for the following VAT periods:

  • February 2020 VAT and Intrastat return filing has been deferred to 6th April 2020,
  • March 2020 VAT and Intrastat return filing has been deferred to 7th May 2020,
  • Quarter 1 2020 VAT and Intrastat return filing has been deferred to 7th May 2020,
  • Annual sales listing has been deferred to 30th April 2020.

VAT Payment

VAT payment in Belgium has been deferred for the following VAT periods:

  • February 2020 VAT payment has been deferred to 20th May 2020,
  • March 2020 VAT payment has been deferred to 20th June 2020,
  • Quarter 1 2020 VAT payment has been deferred to 20th June 2020.

As long as VAT payments are made by these dates for their respective VAT filings, no penalties or interest will be applied.

UPDATE: VAT returns and Intra-community listings with a deadline of 20 April 2020 has been postponed to 5 June 2020. Payment deadline for these returns is also postponed to 20 July 2020.

Bulgaria

VAT Filing

VAT returns should be filed on time, VAT filing deferment measures have not been announced by the Bulgarian Tax Authorities.

VAT Payment

VAT payments should be made on time, VAT payment deferment measures have not been announced by the Bulgarian Tax Authorities.

Croatia

VAT Filing

VAT returns should be filed on time.

VAT Payment

The Croatian Tax Office has been looking into the possibility of issuing a measure for a 3 month VAT payment deferral for all entrepreneurs. This measure would apply from the March 2020 VAT period.

No definitive measures have yet been confirmed and any proposed measures are still being voted on.

In addition, it is also unclear whether these measures would be applied to foreign entrepreneurs who have a VAT number in Croatia.

Cyprus

VAT Filing

VAT returns should be filed on time despite the VAT payment deferment grated by the Cyprian Tax Office.

VAT Payment

The Cyprian Authorities have given the possibility to Tax payers to defer their VAT payments to 10th November 2020 at the latest. No penalties or interest will be applied to VAT payments made up until this date. It is also important to note that VAT returns should still be filed on time.

This VAT payment deferral will only apply to the following VAT periods:

  • VAT period ending on February 29th 2020 for the period covering December 1st 2019 to February 29th 2020 – VAT return to be filed on time for April 10th 2020,
  • VAT period ending on March 31st 2020 for the period covering January 1st 2020 to March 31st 2020 – VAT return to be filed on time for May 10th 2020 ,
  • VAT period ending on April 30th 2020 for the period covering February 1st 2020 to April 30th 2020 – VAT return to be filed on time for June 10th 2020.

Some businesses are exempt from using this deferral measure, these include businesses dealing in food retail, sales of books and newspapers, computers and toys.

Czech Republic

VAT Filing

VAT control statements and returns should be filed on time.

For late VAT control statements for the period of March 1st to July 31st 2020 and for late VAT returns, it is possible to waiver penalties as long as the company can prove how the Covid-19 outbreak has prevented them from filing the VAT control statement and VAT return on time. This can be done by submitting a request to the Czech Tax Office.

VAT Payments

For VAT payment deferral, businesses will have to make an individual request to the Tax Office along with the reasons how the Covid-19 is preventing them from paying the VAT due on time.

Denmark

VAT Filing

VAT returns can still be filed on time.

The EU sales listing and the VAT One Stop Shop filing deadlines remain the same and both should be submitted on time for small, medium and large businesses.

VAT Payment

For small and medium sized businesses paying VAT on a quarterly basis in Denmark, the VAT payments for Quarter 1 2020 and Quarter 2 2020 have been combined and payment will be due on September 1st 2020. For businesses paying VAT on a half-yearly basis, the first and second halves of the year have been combined and payment will be due on March 1st 2021.

For large businesses, the following deferral measures have been put in place:

  • For the April 27th 2020 deadline, VAT return and payment has been extended to May 25th 2020,
  • For the May 25th 2020 deadline, VAT return and payment has been extended to June 25th 2020,
  • For the June 25th 2020 deadline, VAT return and payment has been extended to July 27th 2020.

Estonia

VAT Filing

VAT returns should be filed on time.

VAT Payment

Tax payers can contact the Estonian Tax Office to request the possibility of an extension for VAT payments for difficulties paying VAT due to the Covid-19 situation.

Finland

VAT Filing

VAT returns should be filed on time. However, it is possible for tax payers to request the dismissal of the late-filing penalty, if the difficulty to file on time arose from the Covid-19 outbreak.

VAT Payments

VAT payments should be made on time, but tax payers can request VAT payment deferral from the Finnish Tax Office. This request can also be extended to penalties or interests on late VAT payments.

France

VAT Filing

VAT returns should be filed on time.

VAT payments

VAT payments should be made on time.

The French Tax Office has confirmed however that companies facing difficulties preparing VAT returns and making VAT payments due to the Covid-19 situation are allowed to make a basic estimation of the VAT owed for the month, and to then make a deposit of this amount the following month - the margin for error in the calculation of the VAT estimate is 20%.

For companies facing reductions in their turnover due to the Covid-19 outbreak and ONLY for these companies, they have been given exceptional permission for the duration of the lockdown period in France to make a lump sum deposit of VAT. The way in which the calculation of the lump sum amount will work is as follows:

  • For the VAT return to be filed in April for the period of March:
    • By default, the lump sum amount will be 80% of the VAT amount declared in February, or if in February a deposit had already been made, the lump sum amount will be 80% of the VAT amount declared in January,
    • If activities have entirely ceased since mid-March or have been drastically decreased (to around 50% or more), the lump sum amount will be 50% of the VAT amount declared in February, or if in February a deposit had already been made, the lump sum amount will be 50% of the VAT amount declared in January.
  • For the VAT return to be filed in May for the period of April:
    • The above-mentioned procedure for the March VAT return will be applied if the lockdown period is extended and makes it impossible to file a VAT return with the correctly adjusted tax amount.
  • For the adjusted tax return:
    • Once it is possible to correctly declare the real figures for each month during which the lump sum deposit method was used, and to therefore adjust the tax declared on the VAT returns, all lump sum deposits will be returned to the taxpayer.

The application of these tolerance measures will be subject to later checks and audits.

UPDATE:

  • New deadline for VAT refund claim under the 13rd directive: 30 September 2020
  • Possibility to submit a lump sum of 50% of the VAT amount filed in March (or 80% if the activity has completely stopped).
  • Once the health crisis has ended, submission of a tax adjustment return.

Germany

VAT Filing

At present, VAT returns should be filed on time. There are discussions of implementing deadline extensions for submitting VAT returns, but nothing has yet been approved.

VAT Payment

It is possible for tax payers to request an extension of the VAT payment deadline up until December 31st 2020. Tax payers will need to supply sufficient proof that their activities have been affected by the Covid-19 outbreak.

UPDATE: 2019 Annual VAT return has been postponed until 31 May 2020

Greece

VAT Filing

VAT returns should be filed on time.

VAT Payments

A VAT payment deferral for businesses has been implemented up until August 31st 2020 for VAT return payments due on March 30th 2020.

Hungary

VAT Filing

VAT returns should be filed on time.

VAT Payment

It is possible to request a VAT payment deferral or allowance for partial payments with the Hungarian Tax Office. The administrative fees for this deferral are HUF 10 000.

UPDATE: Live invoices reporting has been postponed to 1 July 2020 (instead of 1 April 2020).

Ireland

VAT Filing

VAT returns should be filed on time.

VAT Payments

For small and medium sized businesses, there are no late payment penalties or interest for the January and February 2020 VAT returns. Other businesses can also request support from the Irish Tax Office for VAT payment difficulties due to the Covid-19 situation.

UPDATE: Late VAT payments for April instalments.

Italy

VAT Filing

For resident tax payers only, all VAT filings have been deferred until June 30th 2020, this includes the 2019 Annual VAT return.

For non-resident tax payers, the 2019 Annual VAT return is due by April 30th 2020. Quarter 1 2020 VAT return should be filed by June 1st 2020 and the corresponding Intrastat is to be filed by April 27th April 2020.

VAT Payment

Currently for non-resident tax payers, VAT in Italy must be paid on time.

Latvia

VAT Filing

VAT returns should be filed on time.

VAT Payment

Tax payers can request a deferment of VAT payment. The Latvian Tax Office has also confirmed that VAT credit refund request declared in returns from March 30th 2020 will be refunded within 30 days.

Lithuania

VAT Filing

There is a possibility of deferring the filing of VAT returns for up to one year.

VAT Payment

There will be no penalties on late VAT payments or interest on any outstanding VAT. It is also possible for tax payers to apply for a complete write-off of any outstanding VAT payments.

Luxembourg

VAT Filing

VAT returns should still be filed on time, however there will be no penalties for any VAT returns filed after the deadline. This will be the case until further notice is given by the administration.

VAT Payment

Businesses can contact the Luxembourg Tax Office to request support should they have any difficulties making their VAT payments on time.

UPDATE:

New deadlines for Intrastat submissions:

  • February 2020: 24 April 2020
  • March 2020: 15 May 2020
  • April 2020: 08 June 2020
  • May 2020: 30 June 2020
  • June 2020: 22 July 2020

Malta

VAT Filing

VAT returns should be filed on time. No notices have been given by the Maltese Tax Office.

VAT Payments

The Maltese government has confirmed a VAT payment holiday for businesses and the self-employed for the periods of March and April 2020. The government has also confirmed that VAT credit refunds will also be accelerated.

The Netherlands

VAT Filing

VAT returns should be filed on time.

VAT Payment

It is possible to apply for a VAT payment deferral with the Dutch Tax Office if a businesses is facing difficulties due to the Covid-19 situation. Upon receipt of the request, the Tax Office will put any VAT payment collection measures on hold as they review the request. No late penalties or interest will be fined for late VAT payment.

Once the deferral request has been approved, there will be an automatic 3 month deferral of VAT payment. This deferral period can also be extended if proof is shown that the 3 months are not sufficient.

Norway

VAT Filing

VAT returns should be filed on time.

VAT Payment

The Norwegian Tax Office has approved a deferral of the deadline for the January/February 2020 VAT payment, for which the original deadline was April 14th 2020, to June 10th 2020.

Further measures have also been put in place by the Tax Office to support companies, these include the reduction of low VAT rates from 12% to 6%. This reduction will apply from April 1st 2020 to October 31st 2020.

UPDATE: SAF-T (transaction reporting) due by 10 April may be postponed on application.

Poland

VAT Filing

VAT return (SAF-T) filings have been deferred from April 1st 2020 to July 1st 2020 by the Polish Tax Office for large companies.

VAT Payment

For companies facing difficulties paying VAT on time, it is possible to request a VAT payment holiday. In addition to this, Polish Tax Authorities are also seeking to process VAT credit refunds on a much quicker basis.

UPDATE:

Intrastat return for April delayed until 20 May instead of 10 May

Portugal

VAT Filing

VAT returns should be filed on time.

VAT Payment

VAT payments in Portugal can me made immediately or in case of difficulties paying due to the Covid-19 situation, they can be made in 3 to 6 monthly instalments without any added penalties or interest. This measure is applied automatically for companies with a business volume of less than 10 million euros, calculated in 2018, or for companies who started their activities from January 1st 2019. Other companies must apply for the measure and should be able to provide evidence that their turnover in Quarter 1 2020 has reduced by more than 20% compared to 2019.

UPDATE: VAT returns for April and May can be delayed until 18 May and 18 June. VAT payment is due by the 25 of the following reported period.

Romania

VAT Filing

VAT returns should be filed on time.

VAT Payment

There is the possibility to defer all tax payments in Portugal, including VAT, that fall under during the state of emergency declared in Portugal. The statement of emergency is covers a 30 day period starting from March 18th 2020 and may be extended. There will be no late payment interest or penalties on VAT paid after the deadline and up to 30 days following the end of the state of emergency. This measure will only apply to VAT that was due during the state of emergency.

Slovakia

VAT Filing

VAT returns should be filed on time.

VAT Payment

VAT should be paid on time. Deferral measures are being discussed by the Slovakian government but nothing definitive has been voted on.

Slovenia

VAT Filing

VAT returns should be filed on time.

VAT Payment

VAT should be paid on time.

Spain

VAT Filing

VAT returns should be filed on time.

The Spanish government has extended the filing period for the VAT returns (including Recapitulative Statements), that must be filed on the 1st quarter 2020 until May 20, 2020, for companies that in 2019 did not exceed the sales threshold in Spain of 600.000 €. This must be explicitely requested and is not granted automatically.

VAT Payment

VAT should be paid on time. For companies who owe under 30 000 Euros in VAT for VAT returns filed between March 13th 2020 and May 30th 2020, there is a possibility to defer the VAT payment by 3 months interest free, or for up to 6 months.

The payment deadline for VAT payable on the 1st quarter 2020 is also extended until May 20, 2020. This must be explicitely requested and is not granted automatically.

UPDATE: VAT registered businesses with a turnover below 600.000€ per year in 2019 can delay filing and payments of their VAT Q1 or monthly submissions until 30 May 2020. Businesses don't need to apply for this postponement.

Sweden

VAT Filing

VAT returns should be filed on time.

VAT Payment

  • Period:
    • For the value added tax (VAT) that is reported on a quarterly basis, you may be delayed for a maximum of one accounting period.
    • For example, you may be delayed with the VAT you have reported in your VAT return for the January – March 2020 accounting period if you submit a VAT return on a quarterly basis.
  • Cost of interest and deferred tax: You pay an interest rate and a deferred fee on the deferred amount. The interest rate and the fee are decided by the Riksdag.
  • Interest expense: The interest rate is currently 1.25 percent. The interest is added to the amount you have received in deferment. When you then pay the tax and the fee, you also pay the interest.
  • Deferment fee: In addition to interest, you will have to pay a special deduction fee. The fee is 0.3 per cent on the granted deferred amount. The fee is charged per commenced calendar month from the month after the deferment is granted up to the month you will pay the deferment. You also pay the deferral fee at the same time as the tax and interest rate.
  • How much can I defer? You can at most get deferred with the entire amount that you report in your employer declaration and in your VAT return for the period to which the application relates.

Switzerland

VAT Filing

VAT returns should be filed on time.

VAT Payment

VAT payments should be made on time.

United Kingdom

VAT Filing

VAT returns should be filed on time.

VAT Payment

For VAT payments due between March 20th 2020 and June 30th 2020, it is possible to pay VAT as usual or companies can opt to pay VAT at a later time. No penalties or interest will be applied to late VAT payments. This measure applies to both resident and non-resident tax payers.

If businesses choose to use this measure, any deferred VAT payments should be made on or before March 31st 2021 at the latest.

It is not necessary to inform HMRC of your choice to defer your VAT payments as it is automatically applied.

This measure does not apply to VAT MOSS payments, which must continue to be paid on time.

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