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Customs Warehouse: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 12 rulings · 2014–2023

Current position

The removal of goods from a customs warehouse does not constitute an import if the delivery is exempt under Article 25 of the IVA (Value Added Tax) Law. The actual transport of the goods may be justified by any means of proof admitted in law. The application of the rebuttable presumptions (iuris tantum) of Article 45 bis of Implementing Regulation (EU) No 282/2011 is permitted to simplify the accreditation of transport.

The DGT's position remains constant regarding the application of exemptions for suspended regimes. The evolution shows a trend towards the simplification of the accreditation of goods transport, allowing the use of legal presumptions to facilitate proof of the removal of goods.

Turning points

  1. V2822-23

    Introduces the possibility of using the rebuttable presumptions (iuris tantum) of Implementing Regulation (EU) No 282/2011 to simplify the accreditation of the transport of goods.

Analysis based on 12 of 12 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

12

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