Deferred import VAT: how to avoid paying it at customs

When your company brings in goods from outside the European Union, customs assesses the VAT along with the tariff duties. As a general rule, this VAT is paid to release the goods, and is later recovered through deduction. The deferment regime breaks this sequence: the quota assessed by customs is not paid at clearance, but is instead included in the VAT self-assessment for the period.

The mechanics are found in article 167.Dos of the Ley del IVA (the Spanish VAT Act) and article 74 of its Regulation, and this is what the AEAT (the Spanish Tax Agency) includes in box 530 of form 036. Once in the regime, the amount is entered in box 77 of form 303 as import VAT assessed by Customs pending payment and, in that same self-assessment, it is deducted as input VAT on imports.

If your company deducts one hundred per cent of the input VAT, the effect of the import on the settlement result is 0. What changes is not how much you pay, but when: you stop advancing the quota at each clearance and financing Hacienda (the Spanish tax authority) until you recover it.

The regime belongs to VAT, so it refers to the entry of goods into the Peninsula and the Balearic Islands. The Canary Islands, Ceuta and Melilla have their own taxes and are not governed by this box.

There is only 1 requirement and it admits no exceptions: the VAT settlement period must coincide with the calendar month. There are 3 ways to achieve this. The first is to be a large company, meaning you exceeded a turnover of €6,010,121.04 in the previous year. The second is to be registered in the Monthly Refund Register (REDEME). The third is to be taxed under the special regime for groups of entities.

The REDEME route is used by importers who do not reach that volume, and it carries a consequence that should be weighed before requesting it: whoever registers is obliged to keep VAT record books through the electronic headquarters of the AEAT, sending billing records on time, and to submit form 303 every month. It is a change of administrative regime, not an isolated procedure.

It also matters who appears as the importer. The regime applies to the entrepreneur or professional acting as such who is the taxpayer for the import, and the option covers all imports for the year: you cannot choose clearance by clearance or reserve it for large shipments.

If none of the 3 routes fit, there is no shortcut. An importer with quarterly settlements pays VAT at customs, no matter how much volume they move.

The window is the month of November, from the 1st to the 30th, of the year prior to the one in which the option is to take effect. It is exercised by submitting form 036 and ticking box 530, with the date in box 736. For the deferment to work during 2027, the option is submitted in November 2026.

It does not need to be renewed. The option is understood to be extended for subsequent years as long as there is no waiver or exclusion, so submitting form 036 again every November adds nothing. This is 1 of the most repeated mistakes.

The waiver is also formulated in November, using box 531 of the same form, and takes effect for a minimum period of 3 years. Anyone who leaves by their own decision cannot return the following year, so the waiver deserves prior calculation and not a last minute decision.

If your company is not yet monthly, registration in REDEME is requested with that same form 036, box 129, and the general deadline is also November. Regarding whether the monthly period must already exist on the day the deferment is requested, the Central Economic Administrative Tribunal, in its resolution of 18 June 2026 (file RG 1021/2025), admitted that the requirement can be proven by simultaneously requesting registration in REDEME. That criterion is not binding doctrine and goes against the one maintained by the Directorate General for Taxes, so it is advisable to plan the operation with a margin and not on the last day of November.

The governing month is not the clearance month or the SAD date: it is the one in which you receive the document containing the settlement carried out by the Administration. The instruction for box 77 says it in those words, and it is the usual cause of end of month discrepancies.

In the self-assessment there are 2 entries for the same operation. The quota goes to box 77 and, at the same time, it is deducted in the deductible VAT block for imports: boxes 32 and 33 for current goods and boxes 34 and 35 for investment goods, provided the quota is deductible. The result of box 69 incorporates box 77 in its formula, so the form only balances when both entries are present.

The electronic headquarters offers the deferred payment import VAT consultation, which lists the deferred quotas for each period, their status and the SAD details. This is the source against which box 77 must be reconciled before submitting, which is better than the accounting entry or the freight forwarder notice.

The submission deadline is that of the monthly declarant: from the 1st to the 30th of the month following the settlement period, except for the January self-assessment, which is submitted until the last day of February.

If you do not include all the quotas notified to you in the form 303 for the period, the difference does not wait for an inspection: it goes directly into the executive collection period, and the AEAT allocates what is declared in order of entry, so what is left out is the most recent. Furthermore, the omission may constitute a tax infringement.

This turns box 77 into a control box, not an estimation box. Under-declaring is not fixed the following month, because the enforcement surcharge has already started on the part not included.

Exit from the regime can also happen without you doing anything. Taxpayers who have opted in are excluded when their settlement period ceases to coincide with the calendar month, and the exclusion takes effect from the exact date the obligation to submit monthly returns ceases. Losing the status of a large company causes this exclusion, unless the monthly period is maintained by being registered in REDEME or by applying the group of entities regime.

That is why the review is not annual out of habit but out of necessity: each year end decides whether you will continue to be monthly in January and, with it, whether the deferment remains in place.

In the Canary Islands, the entry of goods is taxed by IGIC and in Ceuta and Melilla by IPSI. They are not a discounted version of VAT: they are their own taxes, with their own regulations and Administration, so box 530 of form 036 resolves nothing there and state figures are not transferable.

In the chartered territories, the Basque Economic Agreement and the Navarre Agreement are not a bonus either, but their own regulations. Even so, import VAT has a clear state rule: when the taxpayer does not pay taxes entirely to the State Administration, the quota assessed by customs is included in its entirety in the return submitted to the State Administration.

Anyone who pays taxes exclusively to a regional tax authority and has opted to defer submits, for these purposes only, a form 303 to the AEAT for the specific procedure of paying import VAT assessed by customs. In that procedure, only the identifying data, the circumstance of exclusive regional taxation and box 77 are completed.

3 checks organise the entire file. The first is what your settlement period will be in 2027 and through which route: turnover, REDEME or group of entities. The second is that the EORI is active and that the company declaring the VAT appears as the importer on the SAD, because the regime belongs to the taxpayer, not the freight forwarder. The third is an internal circuit so that the customs settlement reaches whoever submits form 303 within the month.

Managora reviews the census and submits form 036 with box 530 within the November window, manages registration in REDEME when it is necessary to reach the monthly period, and submits form 303 for the period with box 77 reconciled against the headquarters consultation. The customs declaration for each clearance is submitted by whoever holds the customs representation for the import; Managora checks that the company declaring the VAT appears on it as the importer. You can see the updated amount for each procedure on its file.