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Customs procedure 42 when importing a machine

Release for free circulation with a VAT exemption because the goods go on to another EU country. The conditions are hard, they come straight from the directive, and the audit arrives later.

Procedure 42 is the release of a machine for free circulation in one EU country combined with a VAT exemption, because an exempt intra-Community supply or a transfer to another Member State follows immediately. Duty is paid as normal. The tax is accounted for in the country of destination, not at the border.

The name comes from the code in the customs declaration: 40 means release for free circulation, 42 means release combined with an exempt supply to another Member State. The legal basis for the exemption is Article 143(1)(d) of Directive 2006/112/EC, and its conditions are set out in Article 143(2).

What the rule actually says

Article 143(1)(d) exempts the importation of goods dispatched or transported from a third country into a Member State other than that in which the dispatch or transport ends, where the supply of those goods by the importer is exempt under Article 138. In other words, the exemption at import is bolted onto the exemption for the intra-Community supply. If the second falls, so does the first. That is the whole mechanism, and it is also the source of most of the trouble.

Conditions that must be met on clearance day

Article 143(2) requires the importer to provide the competent authorities of the country of importation with at least three things at the time of importation. First, the importer's own VAT identification number issued in the country of importation, or the number of a tax representative liable for payment of the VAT, issued in that country. Second, the VAT identification number of the customer to whom the goods are supplied, issued in another Member State, or the importer's own number issued where the dispatch or transport ends when the goods are subject to a transfer. Third, evidence that the imported goods are intended to be transported or dispatched from the country of importation to another Member State, though Member States may allow that evidence to be produced only on request.

Why this matters for an auction machine

The usual set-up looks like this: a Polish company buys a machine at an English auction and wants it at home. There are not two parties here, only one, so there is no classic intra-Community supply. Instead there is a transfer of the importer's own goods under Article 138(2)(c) of the directive. The declaration then carries the buyer's own Polish VAT identification number as the number in the country where transport ends, and in Poland the buyer reports an intra-Community acquisition. This works, but it requires the buyer to be registered for intra-Community transactions on both legs of the operation, not merely domestically.

The reporting duty and what happens if you miss it

This is the point that most often slips. Article 138(1a) of the directive states plainly that the exemption does not apply where the supplier has not complied with the obligation in Articles 262 and 263 to submit a recapitulative statement, or where the statement submitted does not set out the correct information concerning that supply, unless the supplier can duly justify the shortcoming to the satisfaction of the competent authorities. The recapitulative statement is drawn up for each calendar month within a period not exceeding one month. One missing document topples the exemption, and the tax becomes payable in the country of importation.

What an audit looks at

  • Whether the customer's number, or the importer's own number in the country of destination, was active on the date of the transaction.
  • Whether the machine physically left the country of importation. The European Court of Auditors, reporting on procedure 42, recalled that the exemption becomes applicable only when the importer demonstrates that the goods have physically left the importing Member State.
  • Whether the data in the customs declaration matches the consignment note and the purchase invoice.
  • Whether the transaction was reported in the recapitulative statement, in the correct amount.
  • Whether the taxable amount was understated. The same report found operators reporting the statistical or customs value in the recapitulative statement instead of the taxable amount of the import, which also includes transport costs and duties.

When procedure 42 is the wrong tool

There is no point running it when the machine stays in the country of clearance, when the buyer is not registered for intra-Community transactions, or when the transport evidence cannot be gathered in time. Nor is there any point running it for effect: this is a cash-flow instrument, not a way to reduce the burden. If the machine is going to stand in Poland and the buyer prefers to account for import VAT in the Polish return, transit and clearance at home can be simpler, a comparison we draw in clearing a machine in the Netherlands, not Poland. A general description of the mechanism outside the machinery context is in our article on regime 42.

What we do, and what we do not

We organise and run clearance on both sides as part of the job, working with our regular customs agencies, and we supply the transport evidence the whole settlement rests on: a correctly completed and signed consignment note, proof of delivery, and data that matches the declaration. We do not file the recapitulative statement for a client, we do not register anyone for VAT in another country, and we do not represent clients before a tax authority. Those need to be set up with the client's own adviser or accountant before the machine leaves the yard, because they cannot be reconstructed afterwards. The Polish paperwork that follows is covered in VAT and duty on imports from the UK to Poland.

Sources

Planning to bring a machine from the UK to Poland, or on to Czechia, Slovakia, Austria or Hungary? Describe the route in the contact form and we will build the carriage with clearance included. The Central European leg is covered in import from the UK to Czechia, Slovakia, Austria and Hungary. This text is general information, not tax advice.

Frequently asked questions

Does procedure 42 mean no customs duty?
Duty is paid as normal. Procedure 42 concerns value added tax only: it is a release for free circulation with a VAT exemption under Article 143(1)(d) of Directive 2006/112/EC, because an exempt supply or transfer to another Member State follows immediately. Import duty flows from the Common Customs Tariff and is due exactly as it would be on an ordinary release for free circulation.
What happens if I do not submit the recapitulative statement?
The exemption can fall away. Article 138(1a) of Directive 2006/112/EC provides that the exemption does not apply where the supplier has not submitted a recapitulative statement or where it does not set out the correct information for that supply, unless the shortcoming is duly justified to the satisfaction of the competent authorities. Since the exemption at import is attached to the exemption for the supply, losing it makes the tax due in the country of importation.
Can I use procedure 42 buying a machine for my own company, with no customer?
Yes, but as a transfer rather than a classic supply. Where the buyer imports a machine for itself and moves it to its own country, this is a transfer of own goods within the meaning of Article 138(2)(c) of the directive. Article 143(2)(b) then allows the importer to give its own VAT identification number issued in the country where the transport ends. It requires registration for intra-Community transactions and reporting an acquisition in the country of destination.

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