Import VAT Recovery: Why the right documentation matters

Understanding import VAT

Import VAT applies to goods brought into the EU from abroad and is payable in the member state where the goods are imported. Several non-EU countries, including the United Kingdom, Switzerland, and Norway, also impose import VAT under their respective national systems. Therefore, any business importing goods into these countries must correctly account for import VAT.

When can import VAT be recovered?

When import VAT is incurred, the business who has imported the goods typically can recover the import VAT paid. Many jurisdictions offer deferred or postponed import VAT accounting, allowing VAT to be reported on the VAT return rather than paid at the border.
Whether the business pays the import VAT upon importation, or alternatively uses a postponed import VAT mechanism, import VAT recovery is only possible with supporting evidence. Without this, VAT authorities cannot verify or refund the VAT. In verifying the VAT refund, key evidence typically includes customs and transport documents showing information, such as:

• Who owned the goods upon importation,
• Goods entered the country,
• The business recovering the import VAT is stated as the importer of record, and
• The VAT amount being claimed is accurate.

Essential documentation for import VAT recovery

Condition for recovering import VAT and import documentation requirements differ by country, so it is important to understand what evidence can be used to support an import VAT claim in the country of importation before importing. For example,

• EU / EFTA countries: The Single Administrative Document (SAD) can often be used to help evidence importation into the EU.
• United Kingdom: The Import VAT Certificate, otherwise known as a C79 certificate, issued by HMRC upon importation into the United Kingdom can be used to help support a UK import VAT claim.

Generally, import VAT can only be recovered by the owner of the goods during importation, which must be reflected in the supporting import documentation for any import VAT claim. This was reemphasised in the recent UK case TSI Instruments v HMRC [2025] where the business who paid the import VAT was unable to prove they were the owner of the goods during importation and so was unable to recover over £8 million of import VAT.

A common trend across all countries is that without sufficient evidence, VAT authorities will reject import VAT claims, resulting in denied refunds, penalties, interest, and extra administrative costs.

Best practices for compliance

To ensure your business remains compliant and protects its import VAT recovery rights, consider implementing some of the following measures:

1. Consult with VAT specialists: it is always worth discussing import VAT recovery with VAT experts to ensure your businesses import VAT recovery process is compliant with the applicable VAT legislation to avoid import VAT rejection.
2. Verify importer details: Ensure the details on the import documentation reflect the requirements for VAT recovery in the country of importation.
3. Retain all import documents: maintain organised, accessible records.
4. Reconcile regularly: Match customs documents to VAT returns and accounts.
5. Review contracts and Incoterms: Confirm commercial terms support your importer status.
6. Establish clear processes: Obtain and store import documentation promptly after each shipment.

 The benefits of getting it right

Effective import documentation controls:

• Protect your legal right to recover import VAT,
• Reduce audit risk and administrative burden,
• Avoid penalties and delays, and
• Demonstrate strong VAT compliance.

 Schlussfolgerung

In practice, import VAT recovery largely depends on your ability to provide the required supporting documentation. Import documentation is not just administrative paperwork, it is the foundation of your legal entitlement to recover import VAT.

Do not let poor document management be the determining factor in the rejection of a refund of import VAT which you are entitled to reclaim!

If you require any support or have any questions on import VAT recovery, please feel free to contact us.