Import of Goods from Third Countries: VAT, Customs Duty, SAD and Accounting
In brief: The obligation to declare VAT on import arises when the goods are released into the relevant customs procedure, typically release for free circulation. A VAT payer established in the Czech Republic declares VAT on their imports directly in their VAT return. The document for VAT deduction and self-assessment is the decision on the release of goods (SAD).
Import vs. Intra-Community Acquisition of Goods
Import means the entry of goods from a third country into the EU and their release into the customs procedure of free circulation. Unlike acquisitions from within the EU, customs clearance procedures apply and customs duty must be addressed. Exemption from customs duty may only apply in specifically defined cases; VAT applies unless the law provides for an exemption.
Customs Clearance Process
- The supplier issues an invoice and the goods are transported into the EU.
- The declarant submits a customs declaration (electronic SAD).
- The customs authority releases the goods for free circulation. The decisive factor is the date of release stated in the decision.
The decision on the release of goods (SAD) serves as the tax document for claiming a VAT deduction.
SAD – What to Check
- SAD = Single Administrative Document.
- Box 47: the Basis for Assessment of Charges column = basis for customs duty assessment; the Amount column = the customs duty itself.
- Box 48 – Statistical Value: usually completed if the value of a single item exceeds EUR 1,000 or the weight exceeds 1,000 kg. It is not directly decisive for calculating the VAT base.
- Decision format: the decision may be delivered in XML format. For printing or displaying it in a more readable form, the official Customs Administration application may be used.
Accounting Documents
- Supplier invoice including INCOTERMS and currency.
- Decision on the release of goods (SAD) – tax document.
- Transport documents: CMR / B/L / AWB depending on the type of transport.
- Confirmation of payment of customs duty and VAT, if paid during customs clearance.
VAT on Import
- Tax base = customs value + customs duty + incidental expenses up to the first destination within the EU (e.g. transport, insurance), if known at the time of customs clearance.
- VAT return: reported on lines 7 (output VAT) and 43 (input VAT deduction) of the VAT return. Imports are not reported in the VAT control statement.
- Postponed accounting regime: with authorization, VAT may be declared and claimed directly in the VAT return (postponed payment under Section 23a of the Czech VAT Act).
- Exchange rates: the customs exchange rate announced for the relevant month is used for conversion.
Example
Value of goods: USD 10,000
Customs duty 5%: USD 500
Transport costs: USD 500
VAT base in USD: 11,000
Customs exchange rate: CZK 24.50/USD
Base amount in CZK: 11,000 × 24.50 = CZK 269,500
VAT 21%: CZK 56,595
Most Common Mistakes
- Using an exchange rate other than the customs exchange rate.
- Omitting incidental costs up to the first place of destination.
- Posting the transaction in the wrong accounting period based on the invoice date instead of the release date.
- Accounting without the decision on the release of goods (SAD) or incorrect matching of the document.
Customs duty and incidental costs are generally included in the acquisition cost of inventory.
- 131 (504) / 321 supplier invoice for goods
Sources:
- Czech VAT Act – Section 33: Tax Document for Import
- Czech VAT Act – Section 38: Tax Base and VAT Calculation on Import
- Financial Administration: Instructions for Completing the VAT Control Statement – imports are not reported in the control statement
- Customs Administration: Printing the Decision on the Release of Goods (SAD) from XML
- Public Administration Portal: Release of Goods for Free Circulation – information about SAD
- BusinessInfo: VAT Payers’ Procedure for Applying VAT on the Import of Goods