Similar to the majority of economic laws, the product charge law changes from year to year, and 2013 is no exception. Of all the legal regulations applicable from 1 January 2013, perhaps the most important is the change in jurisdiction within the National Tax and Customs Office (NAV) system and the transitional rules in this respect regarding product charge obligations (tax returns, declarations, payments).
From 2013 all of the taxation administration connected to the environmental product charge is carried out by the national tax authority. However, the customs authority that previously oversaw these tasks is still responsible for the official tasks related to waste produced from products subject to the environmental product charge.
According to the transitional rules, missed product charge returns and self-revisions relating to the period prior to 1 January 2013 must be submitted to the customs authority by 14 February 2013. The registration and any correction tasks related to these returns are therefore carried out by the customs authority. From 15 February 2013, however, returns related to previous periods must be submitted to the tax authority. The tax authority will also handle ex post inspections and pre-remittance reviews of product charge returns from 1 January 2013.
This change in authority does not cause any problems in terms of meeting product charge payment obligations, as the previous account numbers remain the same.
1 January is now the date for product-charge registrations as opposed to 14 February. The customs authority is still responsible for matters which arose before 1 January. Thereafter, however, these tasks will be carried out by the tax authority, and a separate form (13TKORNY) has been created for taxpayers to meet their registration obligations. It is important to note here that taxpayers who met their registration and declaration obligations prior to 2013 do not have to repeat their registration on form 13TKORNY – provided there have been no changes in their liability.
Another new feature is that the VPID number does not have to be indicated either on the 13TKORNY registration form or on the new product charge returns. This is because taxpayers subject to the product charge are registered at the tax authority based on their tax numbers.
From 1 January 2013, representatives must be notified on form 13VAMO, but representatives for electronic administration must be notified using form 13T180. Representatives who are entitled to take care of a tax matter based on a previous registration, or who have permanent, all-round authorisation, do not have to register again at the tax authority purely on account of the change in the product charge regulation. This is because the details of previously registered representatives will automatically be transferred from the customs authority to the tax authority.
Following the transfer of data between these two bodies, items related to the product charge can be queried on taxpayers’ tax current accounts.