EXCISE DUTY PAYMENT FOR AUTHORIZED WAREHOUSE KEEPERS TRADING OIL PRODUCTS IN GREECE, OTHER EU MEMBER STATES AND THE UK.
Economic operators engaged with the oil & gas sector in Europe & the UK, including authorized warehouse keepers maintaining local tax warehouses use systems, subsystems and tools like EMCS, FESS, ARC follow up & SEEED. Alongside these are the common legal EU excise framework, regarding tariff classification, procedures and measures, as provided by relevant EU directives, decisions and regulations. Furthermore, there are the country specific fiscal policies including but not limited to the excise duty taxation coefficients per product, the VAT treatment, and the overall approach (set in national level) in terms of excise declarations filled towards the Authorities, guarantees needed and credit line time frames for excise duty payment.
In Greece, Authorized warehouse keepers holding petroleum products in their tax warehouses, can place such products in the local market for consumption ( Gas stations) only by declaring the quantities of different oil products in advance, before exiting the tax warehouse suspension regime. Relevant excise duties & customs VAT are also declared with the oil product quantities and are validated for payment with declarations lodged and addressed towards customs Authorities .Considering that adequate fiscal or bank guarantees have been placed in the name of the Authorized warehouse keeper, actual payment of excise duties and customs VAT is requested by law on the fifth day after declarations made.
In Spain, when considering oil products being set into free circulation and consumption for the Spanish market, the Authorized warehouse keepers maintaining tax warehouses and having placed relevant guarantees are obliged to make payments of excise duties on the twentieth day of the following month, after exit of products from the Tax warehouse. Regarding record keeping, movements and processes, they have to be registered on a daily basis, and sent to the Administration every week.
In Italy, for the same scope and purpose of having oil products set into consumption in the local market, Excise duty & vat payment is due by the sixth day of the following month, while related declarations are made on a monthly basis.
In France, for the same reason, following the exit from the tax warehouse, legislation allows recapitulative fillings made every ten days or even monthly, in case taxation unit of measurement is based on weight. Vat, excise and CSO are to be declared as well when applicable. However, since January of 2021 a new vat taxation scheme is applied, where vat payment is made via FR VAT return.
In Denmark, for excise duties the tax period is the calendar month. The deadline for declaration and payment of excise duties is on the 15th weekday in the following month of the latest tax period. After the end of each tax period, the quantity of products is declared and payment of the excise duties for such tax period is made towards the Danish Customs- and Tax Administration.
For Ireland, excise duties are due on exit from tax warehouse, with revenue permitting a single daily payment to be made for practical reasons. Where guarantee and deferment account is in place, VAT and excise are due monthly on the 15th day of the month following release.
In the UK & North Ireland, immediate payment and completing form W50 at time of removal from duty suspension warehouse is needed.in case there is a deferment account in place, payment is made monthly, in the month after the delivery occurs.
In general, from experience and visibility obtained throughout the years of practice in the sector of petroleum products, the pragmatic lines of trade facilitation tools and processes ( including payments) are drawn in each EU member state or country and reflect certain social & economic indications such as:
The level of trust among Authorities & Traders along with the relevant policies set by the state.
The role of indirect taxes such as excise duties and vat in the annual per Member state national budget.
The consumption index in each country and the general economic status of the country.
The role and control of Oil refineries in the each market.
The availability of solutions provided by other stakeholders including the banking and insurance sector.
A sincere thank you note to all European Excise Association members who contributed the article with important information in reference to their local practice and expertise.