Recently CSNA sought clarification from Revenue with regard to products bought at 23% VAT after the 1st of January. We asked if it is possible that suppliers may be required to provide credit notes and to reissue invoices with the correct VAT. We also sought to have Revenues opinion on whether a retailer is obligated to refund any customer who had the 23% legitimately applied to the product up until the 20th of January.
This is the response that we received from Revenue to our queries.
The backdating of the zero rate has been done on an administrative basis until the appropriate legislation is enacted.
The change in the VAT rate can be dealt with by way of a credit note, so your members could seek a credit note from their suppliers. If they don’t seek a credit note, they can reclaim the VAT they were charged in their VAT return. However, they cannot amend their output VAT without first reimbursing the customers who may have borne the cost of the overpaid tax. On that basis, the only benefit of getting a credit note from the suppliers is a cash flow one for the retailer (i.e. they don’t have to fund the VAT upfront).
We are also providing a Revenue supplied document relating to VAT refunds and ancillary matters – Access here