What keeps us busy about the new “ATLAS Ausfuhr” release

ATLAS 2.4.8.

ATLAS Release 2.4.8.

[Update July 14, 2020]:

With the ATLAS information 0063/20 of July 09, 2020, the announcement was made that for export transactions that are relinquished from July 10, 2020, the follow up procedure will again be started 90 days after the relinquishment. For export transactions that received the status “relinquished” during the period April 24, 2020 and July 09, 2020 the follow up procedure will nevertheless only take effect after 300 days.

[Update June 23, 2020]:

In Participant Information 0042/20 of June 2020, it was announced that types of declaration for which there is no (longer) a legal basis will no longer be available as of July 1, 2020. Thus, in addition to types with the authorization for economic PV of textile products (outward processing), all procedures regarding export declarations with application for export refund will cease to exist.

What is the export refund and who does it affect?

For agricultural products whose prices were generally above the world market level, it was possible to apply for an export refund that made up the difference. These subsidies made it possible for cereals and other products to be sold competitively on the world market.

In 1975, the EEC established basic rules for granting export refunds on cereals and criteria for determining the amount of the refund. In the meantime, several sectors have been added, but the amount of export refunds has been steadily reduced. Thus, in 2013, more than 1.3 million euros were still paid to exporters of agricultural products. The 2013 CAP (Common Agricultural Policy of the EU) reform has now completely eliminated export refunds.

However, it was still possible to apply for export refunds. However, in 2018, it was only about 44 thousand euros. From July 01, 2020 it will no longer be possible to make an export declaration with an application for an export refund using ATLAS software. For this, the complete message group “Pre-notification of a declaration for export” (E_EXP_IND) will be omitted.

What other procedures are being eliminated?

Due to no longer existing cases of application and legal bases, the following procedures with reference to textile products are no longer applicable:

  • Export declarations for entry into the customs outward processing procedure
  • Export declarations for transfer to the economic outward processing procedure
  • Subsequent export declarations
  • Subsequent export declaration for correction
  • Subsequent export declaration from the emergency procedure

Changes in the follow-up procedure

In addition to the discontinuation of various registration types, information was provided in subscriber information 0034/20 that changes exist for the investigation procedure.

What is an investigation procedure?

The last step of a transaction is the exit confirmation, which is transmitted from the customs office of exit to the customs office of export and thus to the software user. This concludes the process and the exit confirmation can be used to prove for tax purposes that the goods have left the EU. If no exit confirmation is received from the customs office of exit, an investigation procedure is initiated. Various circumstances can lead to the fact that goods are not registered by the customs office of exit. Then there is no de facto proof that the goods have been shipped to a third country. For this reason, customs have issued regulations and implemented automatisms in the ATLAS procedure. Within 90 days after an export declaration was given the status “left”, the goods had to have left the EU. If the deadline expires, the routine takes effect, which assigns the status “on resubmission” to goods not registered at the customs office of exit and thus initiates the inquiry procedure.

In the case of an inquiry procedure, the exporter has 45 days to prove with alternative evidence that the goods have nevertheless left the EU. Subscriber Information 0034/20 informed that the number of days has been increased to 300 days.

70 days after receiving the status “surrendered”, it is still possible to independently start the investigation request indicating the actual customs office of exit.

Increasing the duration to 300 days does not only bring advantages, because documents would have to be obtained and transmitted to the customs office of export within 45 days after 300 days in the worst case. It could be the case that certain documents would no longer exist.

Sebastian Baumgarten