VAT compliance obligations - Recapitulative statements
Taxable persons registered under article 10 of the Value Added Tax Act, have various reporting obligations including ‘recapitulative statements’.
A recapitulative statement is a document that taxable persons in the European Union (EU) may be required to prepare and submit to their local tax authorities to report certain types of cross border supplies. The requirement to file a recapitulative statement is part of the VAT control system within the EU in order to ensure that VAT on cross border supplies is correctly declared and paid.
- Who is required to file a recapitulative statement?
- Content of recapitulative statement
- How to submit a recapitulative statement?
- Frequency of submission
Who is required to file a recapitulative statement?
Every person or business subject to VAT is required to file a recapitulative statement in respect of :
exempt intra Community supplies of goods;
the supply of goods in the context of an EU cross border triangulation transaction;
- services provided (non-exempted services for which the customer is liable for VAT in their country of establishment) to taxable persons on which VAT is due in another EU Member State in terms of the reverse charge provisions; and
- certain transfers of own goods between EU Member States
It is important to note that failure to submit a recapitulative statement on time, would render an exempt intra-Community supply of goods taxable.
Content of recapitulative statement
Recapitulative statements (whether for goods or services) must contain:
the country code and the VAT number:
of the customer purchasing the goods or the recipient of the goods in the context of a triangular transaction; or
of the recipient of the services;
the total sales value in Euro of the goods delivered or services provided to the same buyer within the EU;
where applicable, any corrections to data provided in previous recapitulative statements.
How to submit a recapitulative statement?
Legal Notice 363 of 2009 requires that recapitulative statements must be submitted by electronic file transfer. These can be submitted by individuals in possession of an electronic identity (e-ID) or, in case of persons non holding an e-ID, by obtaining access through a separate application to be filed with the office of the Commissioner for Revenue.
Frequency of submission
Recapitulative statements must be filled at least on a calendar quarterly basis. However, in the case where the value of intra-Community supplies of goods to be reported in a recapitulative statement exceeds €50,000 during any calendar quarter or during any of the previous four calendar quarters, then recapitulative statements (showing supplies of both goods and services) must be filled on a monthly basis. The filing deadline in each case is the 15th day of the month following the particular reporting period.
The Value Added Tax Act provides for penalties in case of late submission of, or failure to submit, recapitulative statements. Indeed in the 2023 Budget Measures Implementation Bill proposes that the penalties for the late submission of a recapitulative statement to increase to €50 monthly capped at €600 for every recapitulative statement not submitted by its due date.
How can PwC assist you?
We can assist you with analysing your supplies to determine whether a recapitulative statement is required and we can also assist with submitting your business’ recapitulative statements. Please contact us for further details if you wish to delegate this function to our firm.
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