Mixed and partial VAT payers: Extended submission deadline for VAT real use deduction method


Mixed VAT deduction, particularly prevalent among real estate, financial and holding entities, has seen significant changes since last year. For mixed and partial VAT payers employing the real-use deduction method, new specific annual information submission requirements have been introduced, necessitating submissions through the Intervat system.

The required information to be submitted in 2024 includes:
  • Full VAT Deduction Operations: The percentage of VAT attributed to activities that are exclusively within sectors eligible for full VAT deduction.
  • No VAT Deduction Operations: The percentage of VAT associated with operations that are solely within sectors not eligible for VAT deduction.
  • Mixed Operations: The percentage of VAT for activities that span sectors both eligible and ineligible for VAT deduction.
  • Special Proratas: Submission of any special prorata percentages as applicable to your operations.

Given the complexity of these calculations, which often cannot be directly extracted from standard accounting software and require manual input and analysis for accurate allocation, the Minister of Finance has acknowledged these challenges and extended the submission deadline.

Extended Deadlines for 2024:
  • Quarterly Filers: The deadline for the 2nd quarter 2024 declaration has been extended to July 20, 2024. An additional extension to August 9, 2024, is available to accommodate the summer holiday period.
  • Monthly Filers: June 2024 declarations are now due by July 20, 2024, with the same extension to August 9, 2024, applicable for the summer holiday period.
In this year’s initial declaration, taxable persons are allowed to submit estimated figures, acknowledging the difficulty of precise calculations. However, the accurate final figures must be reported in the subsequent periodic VAT declaration:
  • Quarterly Filers: Must submit final figures by the 3rd quarter 2024 declaration, due by October 21, 2024.
  • Monthly Filers: The final figures for November 2024 must be submitted by December 20, 2024.

For mixed VAT payers applying the general prorata, the delay to report the final and temporary general prorata in the periodic VAT return is a priori also shifted from April to July.

Increased scrutiny through audits is anticipated for mixed VAT payers. This highlights the urgent necessity to rigorously evaluate and, if needed, revise your VAT deduction approach to ensure it is both robust and compliant.

Our team is prepared to offer guidance, ensuring your VAT tracking and allocation methodologies are efficient and in line with the VAT rules and best practices.