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From 1 January 2022, the DEB will be duplicated

At Fiscalead, we used to tell our foreign clients that in France Intrastat and the EC Sales list were combined into a single reporting obligation: the DEB (déclaration d'échanges de biens). The year 2022 will break away this habit. In this article, this article details the changes that await you from January 2022.

As of January 1st 2022, the current version of the DEB is repealed. It will be replaced by these two separate declarations:

  • The statistical survey declaration. It is commonly referred to in the European Union as "Intrastat".
  • The VAT recapitulative statement for intra-EU supplies of goods. It is commonly referred to in the European Union as the "EC Sales list". 

In the light of an update of the European standard, the French regulation on the DEB had to be modified. We detail here below the impact of this change.

The statistical survey declaration ("Intrastat")

Statistics are crucial at all levels, including from a customs perspective.

Above all, this declaration is intended to provide data on foreign trade. Thus, it should be provided at the request of the customs administration. Indeed, the companies liable for this declaration will receive a postal mail addressed to their registered office by the end of December 2021. If they do not receive this letter, they will not be liable for the statistical survey.

Please note: A company should not spontaneously declare a response to a statistical survey at this stage of the statistical survey roll-out. Only companies that have received a request from the customs administration will be required to do so.

The statistical survey report adds new variables:

  • The "country of origin" on dispatch (regims 21 and 29): 
    • For the purposes of the statistical survey, the "country of origin" is determined by reference to customs rules.
    • For customs purposes, the "country of origin" is not the "country of dispatch" of a good.
  • The goods, in the production of which more than one country or territory is involved, shall be considered as originating in the country or territory where they underwent their last substantial processing or working: 
    • economically justified, 
    • carried out in a company equipped for this purpose 
    • and which has resulted in the manufacture of a new product or representing a significant stage of manufacture. 

Currently, this information must be filled in only on the DEB for arrivals.
From January 2022, this variable will also have to be filled in on dispatch.

  • The "customer's VAT identification number" for regim 29 on dispatch:
    • shipments of goods for assembly or installation
    • shipments of goods to perform customs export formalities in another Member State
    • shipments of goods to a Member State for the purpose of supplying a service (tolling work, etc.)
  • If the regim 21 is used, the variable "customer's VAT identification number" is always required.

Companies liable for this Intrastat obligation will have to provide a single reply per month. They must also do so by type of flow (introduction/dispatch). Warning: The response to this statistical survey will be compulsory even if there is no flow for a given month.

In conclusion, if you are used to submit DEBs, this is an important change to note. Previously, no flows on a given month would give raise to no DEB obligation.

The VAT summary report ("EC Sales list")

NASA Earth Observatory/Robert Simmon/Chris Elvidge/NOAA

The tax information in the VAT recapitulative statement is intended for the tax administration. It is also intended for data exchanges between the tax authorities of several Member States for the control of intra-EU VAT.

Thus, companies making intra-Community supplies of goods must, from the first euro, spontaneously file the VAT recapitulative statement. They do so by indicating the tax information for which they are liable. Only one VAT recapitulative statement will have to be provided per month and per company.

The customs administration will continue to be responsible for collecting the VAT recapitulative statement on behalf of the tax authorities.

Businesses carrying out intra-EU supplies of goods must take into account the consequences of these new declaration procedures. Indeed, since the entry into force of the "quick fixes" on January 1st 2020, the VAT exemption of intra-EU supplies of goods is conditioned, in particular, to the submission of the recapitulative statement and the fact that its data are correct and complete.

Sources: DSECE Note to operators n°21000040 of 4 June 2021.

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