Starting from November 1, 2025, and throughout the entire month, companies and professionals may apply for the deferred VAT regime for imports made from January 1, 2026 onwards. The application must be submitted to the Spanish Tax Agency (Agencia Tributaria) through the Census Declaration (form 036), selecting the option corresponding to deferred VAT.

The deferred import VAT regime allows the VAT amount settled by Customs not to be paid at the time of customs clearance together with the rest of the duties on the import declaration (DUA), but instead to be included directly in the VAT return (form 303) corresponding to the period in which the importer receives the customs settlement document.

In this way, the tax amount is declared and offset within the same VAT return, avoiding the financial impact of having to advance the payment of the import VAT. In practice, for many taxpayers, the economic effect is practically neutral, since both the input and output VAT are recorded in the same periodic return.

Requirements to apply for deferred VAT

To qualify for this special regime, the following conditions must be met:

• Be a business or professional acting as such for VAT purposes.
• Have a monthly VAT return period, either by being registered in the REDEME (Monthly VAT Refund Register), by being classified as a large company, or by belonging to a VAT group.
• Request the application of deferred VAT within the established period, that is, from November 1 to 30, 2025, by submitting form 036.

Once the option for deferred VAT has been exercised, it will automatically remain in force for subsequent years, unless an express renunciation is submitted. Such renunciation must also be made through a Census Declaration within the established deadline (usually during November of the year prior to when the renunciation takes effect).

Effects on guarantees and customs management

Companies under the deferred VAT system do not need to include import VAT amounts in the calculation of the reference amount of the customs guarantee. However, there is an exception: when the guarantee is to be used in the transit regime or can be used in more than one EU Member State, the VAT amounts must be considered for calculation purposes.

This system is particularly aimed at regular importers, who would otherwise have to make periodic VAT payments with a significant impact on their cash flow. With deferred VAT, the tax is integrated into the regular VAT reporting process, promoting a more efficient management of liquidity and financial resources.

More information

• Spanish Tax Agency – Information on deferred VAT for imports