Should the draft of Bill be approved, this modification will be applicable as of 1st January 2016, being necessary to review the current set-ups in order to adapt them to the new regulation. As a general rule, the main modification will affect the importations of goods put under a VAT warehousing regime by the time of their arrival to the Spanish territory.
In this respect, the draft of Bill foresees two technical amendments: i) the release of goods from the VAT warehousing regime to be exported or shipped to another EU Member State will not trigger the taxable evente transaction tantamount to an import, and ii) the supply of services in relation to goods stored within a VAT warehouse will only be exempt provided such goods have been imported within the Spanish territory and such importation has qualified as an exempt import in accordance to article 65 of the Spanish VAT Act.
It should be noted that Article 65 of the Spanish VAT Act will suffer also a modificaction to the extent that the new wording reduces the list of goods that will qualify for the the application of such an exemption. As per such, our understanding is that the current application of the VAT warehousing regime will be restricted to some specific listed goods and thus we recommend to analyse the impact of the future amendments.
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