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Tax border customers and the recapitulative statement

If a company registered for VAT sells goods to private individuals or to organisations or companies not registered for VAT, it can apply for status as a tax border customer. Customs gives the tax border customer a tax border number for use as identification in declarations and on goods consignments.  

What should tax border customers do? 

  • The tax border customer submits the import declaration as a recapitulative statement in the Customs Clearance Service on behalf of a party who is not registered for VAT. Tax border customers can use a representative to submit the declaration. Please note, however, that it is currently not possible for representatives to use the Customs Clearance Service when submitting the declaration. Instead, representatives should contact Customs on skattegrans@tulli.fi, and Customs will submit the declaration.
  • The tax border customer pays the VAT to Customs 
  • The tax border customer submits a VAT return to the Tax Administration.
    The tax border number is only used in the trade between Åland and mainland Finland. 

How to apply for a tax border number

  • Fill in the application for a tax border number 580 (available in Finnish and Swedish, link to Finnish version) and send it to the following address: Mariehamns tull, PB 40, 22101 Mariehamn.
  • If your company changes its business ID, apply for a new tax border number using the above-mentioned form.

Transport of goods

The transport company or other transporter of the tax border customer’s goods must submit a presentation notification for the shipments. The goods consignment must bear the company’s Business ID and tax border number.

Recapitulative statement 

A tax border customer must submit a recapitulative statement and pay the import VAT for those consignments for which import VAT has been collected from the customers on behalf of Customs. 

  • A mandatory detail in the Customs Clearance Service is the trader office. If the service has not filled in this detail, it must be filled in manually. The trader office code is usually 000.
  • The trader reference is a mandatory detail at header level. For example, the reference can comprise the month and year of the statement (01/2023).
  • In a recapitulative statement, provide the first day of the tax period (= calendar month) as the tax determination date.
  • In the statement, there is no need to specify the importers receiving the goods. Instead, the code FIKIR must be provided under additional information and, as its description, a reference number or some other detail based on which more information about the consignees can be found in the company’s records. For example, a client list can be used as reference.

If the goods you have sold are returned, for instance if the commercial transaction is cancelled, you should note certain things in your bookkeeping and when notifying the amendment to Customs.

This guidance replaces previous instructions regarding goods returned to sellers who use a tax border number.

Bookkeeping

Make the adjustment entry for the calendar month under which the entry is to be registered in accordance with good accounting practice. Make the entry for the month when you regained control of the goods, regardless of whether it happened during the month of sale or afterwards.  
Amendment

You can amend the details for the returned goods either using the recapitulative statement or by submitting an amendment request (request for administrative review). Check the situations of use:
1. Amendment using the recapitulative statement

You can make the amendment in a recapitulative statement in the Customs Clearance Service if, in the month concerned, you are required to pay at least the same amount of value added tax as the adjustment entry amount to be indicated in the recapitulative statement. 

  • When the goods have been returned and you have registered the sale as cancelled, refund the buyer the VAT-free selling price and the import VAT you have collected on behalf of Customs.
  • Submit an import declaration for the goods. The declaration should indicate the treatment of the goods as returned items as the basis for tax exemption, and contain the additional information needed for verification, such as a reference to the bookkeeping entries regarding the original sale.
  • Itemise the details on each sale on individual rows, as well as the details on adjustment entries again on their separate rows.
  • Provide the additional information using the code FIXXX. If there are several declarations that need amending, you can make out a single supporting document for the accounting records and provide the ID of that document (accounting document number) in the recapitulative statement.

2. Standard amendment request (request for administrative review)

You can make the amendment as a standard amendment request if, in the month concerned, the amount of VAT collected for payment to Customs is smaller than the adjustment entry amount to be indicated in the recapitulative statement.

  • This option must be used when goods are returned to you during a month where you have not collected enough VAT in connection with sale for payment to Customs. In such cases, it is not possible to note the refund on the recapitulative statement, as the refund amount would be higher than the amount of import VAT to be paid to Customs based on the recapitulative statement.
  • An invoice that indicates whether the sale was subject to tax or not must be enclosed with the amendment request. You are also required to present a credit note that you have sent to the customer, or some other documentation on the refund of the selling price, as well as the MRN of the customs declaration and the number of the recapitulative statement.