Expired MRN After 11 Months

Initial Situation

A customs agency from southern Poland was conducting an internal audit of open export declarations. During the review, they discovered that one declaration - for an export of industrial machinery via Rotterdam - had remained open for 11 months.

The tax office, as part of a routine inspection, had already sent the exporter a request to explain the missing proof of export. Without the export confirmation document, the company could not prove that the goods had actually left the European Union, putting the application of the 0% VAT rate in jeopardy.

The export was valued at over EUR 380,000. A potential VAT correction would have meant an obligation to pay the output tax plus interest - a significant financial burden for the exporter.

Complication

After initial analysis, it turned out that the container had been transhipped in Rotterdam from one vessel to another. The shipping line had changed the loading plan, and the container sailed on a different vessel than originally scheduled. The data in the Dutch port system had not been updated - the system was still expecting the container to be loaded onto a vessel that had long since departed the port.

Additionally, because more than 150 days had elapsed since the export declaration date, the Polish office of export had initiated an enquiry procedure. The standard automatic MRN closure path was no longer available - manual intervention and coordination with the Dutch customs authority were required.

Our Action

The case required working on several fronts simultaneously. Here is what we did:

1. Reconstruction of the container's history - we traced the complete route of the container: loading in Poland, transport to Rotterdam, transhipment to the second vessel, and departure from the port. We confirmed that the goods had indeed left the EU customs territory.
2. Obtaining the archived shipping manifest - we obtained data from the manifest of the vessel onto which the container was actually loaded. The manifest confirmed the date and circumstances of the goods' departure.
3. Updating data in the port system - we corrected the information in the Dutch port system, replacing the original vessel data with the data of the vessel the container was actually loaded onto.
4. Coordination with Dutch customs - because the 150-day deadline had been exceeded and an enquiry procedure had been initiated, direct communication with the Dutch customs authority was necessary to obtain retroactive confirmation of export.
5. Delivery of the export confirmation - after the MRN was closed in the customs system, the export confirmation proof of export was generated and forwarded both to the client and to the Polish office of export.

Result

The MRN was closed retroactively - the Dutch customs authority confirmed the export based on the updated port data and shipping manifest. The export confirmation was generated and delivered to the client and the Polish tax office.

Thanks to swift action, the exporter avoided a VAT correction and the associated interest charges. The entire process - from the moment the case was submitted to delivery of the export confirmation - took 8 business days. The longer-than-standard timeline was due to the need for coordination with the customs authority and retrieval of archived data.