If you’re a taxable person registered under Article 10 of the Value Added Tax Act, VAT compliance comes with several reporting requirements, recapitulative statements being one of them. These statements play a key role in cross-border trade within the European Union (EU), ensuring VAT is reported correctly and in line with European legislation.
At PwC, we’re here to help you make sense of these obligations, so you can remain compliant, avoid penalties and focus on what matters most: growing your business.
- What is a recapitulative statement?
- What must be included in a recapitulative statement?
- How do you submit a recapitulative statement?
- Frequency of submission
What is a recapitulative statement?
A recapitulative statement is a document that taxable persons in the EU need to submit to local tax authorities detailing specific cross-border transactions within the EU. It forms part of the EU’s VAT control system and helps verify that VAT is being applied and declared correctly across Member States.Who is required to file a recapitulative statement?
Every person or business subject to VAT is required to file a recapitulative statement for the following transactions:
- exempt intra-community supplies of goods;
- the supply of goods in the context of an EU cross border triangulation transaction;
- services provided (which are non-exempted and therefore where 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 missing the deadline can turn an exempt supply into a taxable one, potentially triggering VAT liabilities you weren’t expecting.
What must be included in a recapitulative statement?
Each recapitulative statement, whether its for goods or services, must contain the following:
- 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 do you 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 filed 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 monthly. 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, the 2023 Budget Measures Implementation Bill proposed that the penalties for the late submission of a recapitulative statement increase to €50 monthly capped at €600 for every recapitulative statement not submitted by its due date.
How can we help?
Understanding the rules is just the start. At PwC, we help you assess your business activities to determine when recapitulative statements are required and take care of preparing and submitting them on your behalf.
Let us handle the complexity, so you can stay focused on running your business with peace of mind
Do you need help?
Contact us to learn more about how we can support your VAT compliance.
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