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Proof of cross-border transportation - EU VAT Quick Fixes

  • Dec 27, 2019 | Richard Asquith

The third of four EU VAT quick fixes concerns evidence of transportation. Goods sold cross-border within the EU on a (business-to-business) B2B basis are exempt from VAT. One of the key conditions of this simplification is that there is adequate proof held by the supplier that the goods did leave its country. 

Current position – differences on proof of movement of goods

Currently, the rules of proof of cross-border transportation vary across the EU member states. 

This can result in legal uncertainty on the treatment and liability for VAT by the supplier and customer. It has also meant that businesses have incurred a disproportionate expense in maintaining varying systems to support the EU proof of movement rules. 

What’s changing on 1 January 2020 

The EU is harmonising the documentary evidence rules from 2020. Two options may be selected to satisfy the new, pan-EU rules on proof of cross-border movement for goods to qualify for a VAT exemption: 

  1. The supplier is responsible for the movement of the goods. The supplier must retain two pieces of non-contradictory evidence that the goods where transported to the customer’s member state. See list of documents below; or 
  2. The customer is responsible for the movement of the goods. The supplier must obtain written evidence of the transport from the customer, supported by two pieces of evidence as detailed belwo. 

What documentary evidence required for quick fixes?

The new rules specify two lists of documentary evidence. Suppliers must retain: 2 documenent from list A; or 1 from list A plus 1 from list B:

  • List A: Signed CMR road transport document; Bill of Lading; Airfreight invoice; courier invoice.
  • List B: Insurance policy for the transport of the goods; official documentary proof or arrival of the goods; or receipt by operator of receiving warehouse in country of arrival.


VP Global Indirect Tax
Richard Asquith
VP Global Indirect Tax Richard Asquith
Richard Asquith is VP Global Indirect Tax at Avalara, helping businesses understand their compliance obligations as they grow globally. He is part of the European leadership team which won International Tax Review's 2020 Tax Technology Firm of the Year. Richard trained as an accountant with KPMG in the UK, and went on to work in Hungary, Russia and France with EY.
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