- Transition to CC599C Message: Effective October 31, 2024, the IE-599 message used for confirming exports has been replaced by the CC599C message due to the implementation of the AES/ECS2 PLUS and NCTS2 PLUS systems. Despite the change in nomenclature, the CC599C will continue to serve the same tax function, providing the basis for applying the 0% VAT rate on exports.
- Documentation Flexibility: While the CC599C message is now the primary document for proving exports, businesses should note that other forms of documentation can also support the application of the 0% VAT rate. This includes alternative evidence such as consignment notes, declarations from carriers, and customs documents from non-EU countries, especially in cases where the IE-599 or CC599C is unavailable.
- Focus on Substantive Evidence: The key factor for applying the 0% VAT rate is the actual export of goods outside the EU, not merely the possession of specific documents. Tax authorities should not deny the right to apply the 0% rate solely based on missing documentation, as long as the export can be substantiated by other evidence, aligning with recent court rulings that emphasize the importance of proving the fact of export rather than adhering to rigid documentation requirements.
Source legalis.pl