Intrastat is the system for collecting statistics on physical movements of goods between Member States of the European Union (EU).

All Irish VAT registered traders are required to complete boxes E1 and E2 of their Irish VAT3 returns (boxes for EU dispatches and arrivals of goods), however only VAT registered traders who exceed the relevant annual thresholds, are required to complete separate detailed monthly Intrastat statistical declarations.

Currently the annual thresholds are €635,000 for dispatches of goods from Ireland to the EU and €500,000 for arrivals of goods from the EU into Ireland. These thresholds are regularly reviewed and could change in the future.

Intrastat is an important source of information for our Government and the EU. It is therefore important that the statistical information submitted by traders is both timely and accurate. As traders are full responsibility for the data provided, the onus is on traders to supply the correct set of information and most of all, to stay up to date with Intrastat reporting requirements. Failure to do so may lead to queries from both Revenue and the statistical office as well as non-deductible penalties.

These reporting requirements will change in 2022. Revenue and the Central Statistics Office have added two fields that will become mandatory from 1 January 2022.

From that date both the “Identification Number allocated to the partner operator in the Member State of destination” as well as “the Country of Origin of the goods”, will have to be included in your Intrastat declarations for dispatches.

1. The Customers’ Identification Number
   
2. The Country of Origin
   
3. Amendments to Harmonised System (HS) Nomenclature
   

The “Identification Number" allocated to the partner operator in the Member State of destination” should be the VAT number of the EU customer to whom the goods are physically delivered. Note that in triangulation scenarios, this number should be the VAT number of the entity who receives the goods. In the absence of VAT number (e.g. B2C sales), the Irish trader will need to confirm this on ROS before submitting his/her INTRASTAT declaration.

The “Country of Origin" of the goods on the other hand, refers to the place of production of the goods. Note, that the country of origin can be any country in the world and is not limited to the EU. In that regard, goods entirely obtained in one country will originate in that country whereas goods produced in more than one country will originate in the country where the last substantial transformation processing took place. This excludes splitting of packages and re-labelling of goods.

The Central Statistics Office have advised that both the ROS filing system and the Intrastat forms will be updated accordingly to include these new fields.

To be able to meet these new Intrastat requirements, we would encourage you
to start adjusting your internal system and update your compliance team at an
early stage.

The 2022 edition of the HS was approved in June 2019 which will enter into force 1 January 2022. The new edition aims to keep HS nomenclature up to date in terms of changes in technology or patterns of international trade. The new HS 2022 edition makes some major changes to the Harmonized System with a total of 351 sets of amendments covering a wide range of goods. The amendment  includes specific customs classifications including (but not limited to) placebos and clinical trial kits for medical research, cell cultures, novel tobacco and nicotine-based products, electrical and electronic waste, smartphones, glass fibres, metal forming machinery, toxins to laboratory equipment.

Should you have any queries on the contents of this article or if you would like our assistance with ensuring that you are compliant with Intrastat, the Deloitte Intrastat (Mikael Garcia) and Customs specialists (Goker Yuruk) can provide
training, consultancy and compliance solutions to minimise the risks.

Note: These Intrastat changes are part of the Framework Regulation Integrating
Business Statistics (or “FRIBS”) set up at EU level and implemented via Regulation (EU) 2019/2152 on European business statistics and Regulation (EU) 2020/1197 laying down the related technical arrangements. The purpose of FRIBS is to collect information that would help in the future to reduce the reporting burden on businesses and the number of traders who are required to submit detailed Intrastat declarations. One of the objectives will be that data on EU exchanges is collected through a future data transmission hub which will be administered by Eurostat.