In practice, as per November 4 the Spanish Customs authorities will check that the place of establishment of the EORI number corresponding to the exporter mentioned at box 2 in the export declaration (SAD), appearing at the European EORI database, is in an EU Member State. If such EORI appears as registered with a non-EU place of establishment the SAD will be rejected.
What if you don't meet this requirement?
Non-EU resident companies that do not meet this condition may consider using the services of a third party (i.e. qualified service provider) that meets the requisite of being EU Customs established and which may appear as exporter of the record on their behalf.
Please note that non-EU resident companies having obtained an EORI in Spain with a Spanish tax representative, would appear ex-officio with their Spanish tax domicile at the official address of this representative. For this case, it is contemplated that the company allows its data at the Spanish census to be shared for EORI database purposes which, if accepted, would result in the company appearing in the database as established in Spain.
How can Pincvision support you?
Do you have any questions or are you looking for support with your VAT or Customs processes? Pincvision is always happy to help you. Please contact us by sending an email to firstname.lastname@example.org or call +31(0)88-4321800. We are happy to assist you!
Daniëlle van der Meulen-Idema
Sr. VAT Specialist