Which documents are needed for an export (code 10): how does one set of documents serve customs, the tax authority and accounting?

"Silliq Tosh" LLC makes granite slabs. A contract worth 24 000 dollars has been signed with a construction company in a neighbouring country, and the slabs are shipped in a railway wagon. The company's lawyer, logistics manager and accountant each ask for their own document, and in the end three copies of the same paper pile up in one folder. In fact export documents are needed at four addresses, but many of them serve several purposes at once. Knowing this makes the job much easier.

Who needs export documents and why?

What is submitted to customs for an export?

For export the Code does not give a complete list of documents: the list of documents required for clearance is set by the Cabinet of Ministers (part one of Article 31). The government resolution on declaring goods in force is Cabinet of Ministers Resolution No. 605 of 31 July 2018 (as amended by Resolution No. 630 of 4 October 2024). Its paragraph 2 approved the Regulation on the procedure for declaring goods (Appendix 1). The former Resolution No. 197 has been repealed. Appendix 1a of the same resolution (minimum invoice data) applies only to the invoice for goods imported into the republic, that is, an import invoice; it sets no requirements for an export invoice.

Resolution No. 605 does not give a single closed list of documents for export either: permits needed depending on the type of goods may also be set by other regulations. That is why a "complete list" is not reproduced in this article. Check the list of documents required for clearance on the official website of the State Customs Committee (the last part of Article 249 of the Code requires this list to be published on that website). The Code does say three things precisely:

• if the goods require a permit, customs independently checks that it exists in its information system (part two of Article 31);
• the cargo customs declaration is submitted by the declarant or the customs broker (Article 258);
• for goods being exported the declaration is submitted before they are actually taken out (Article 261). The import period of "fifteen calendar days from the day the goods are presented to customs" does not exist here.

The accompanying documents, that is, the commercial and transport documents, are used in the same sense in an export (Article 9). For "Silliq Tosh" these are the contract, the invoice, the packing list and the railway waybill.

What does the carrier show at the border?

Under Article 19, on exportation the carrier presents two things: the customs declaration or another document allowing exportation, and the documents and information listed in Article 18 for the type of transport. Since the "Silliq Tosh" cargo goes by rail, item 4 of Article 18 applies:

For road, water and air transport the list of documents is different. It is given in full in the table in the article "Which documents are prepared for an import (code 40)", because on exportation Article 19 also refers to exactly the same Article 18.

Which documents and which date matter for 0% VAT?

Under the Tax Code, the zero rate applies to the sale of goods exported under the export customs procedure (Article 260, part one, item 1). The documents proving this right are submitted together with the tax return (last part of Article 260). Their complete list is in Article 261. It is given in a table, together with the calculation of the zero rate and the refund of input VAT, in the article "0% VAT on export", so it is not repeated here. In this article another question matters: which document from Article 261 also works for customs and accounting. The answer is in the matrix below.

From the documents' point of view, what matters is the date. On export the date of supply for VAT is the date the border is actually crossed. Under periodic or temporary declaration, the date the CCD is registered with the customs mark is used instead (Tax Code, Article 242). Article 261 confirms the border crossing in two ways: accompanying documents bearing the mark of the customs authority at the crossing point (item 3 of part one) and the electronic data that customs authorities send to tax authorities in real time (part two). So for VAT the most important paper is the accompanying document with the border mark.

On the basis of which document is revenue recorded?

In accounting a different test applies. Paragraph 16 of NAS No. 2 sets five conditions for recognising revenue from the sale of goods. From the point of view of choosing a document, the first is decisive: «the significant part of the risks and rewards» of owning the goods must have passed to the buyer.

When the risk passes is determined by the delivery term in the contract (its code is entered in the CCD under Annex 7). The "Silliq Tosh" contract states that the risk passes when the slabs are handed over to the railway at the station of departure (hypothetical example). So for accounting the decisive document is the acceptance date in the railway waybill. For VAT, however, the date of the border mark is needed. If the wagon crosses the border in another month, the two dates fall into two different months.

Journal entries (amounts and rates are hypothetical):

Now let us look at the set in one matrix. Each cell shows the rule that requires the document or relies on it. "No" means the document is not mentioned by name in that source:

Practical tip: what to watch for in export documents?

The following are the author's recommendations (practical tip):

1. Write the risk-transfer point clearly in the contract and also state which document confirms it: a waybill, a handover certificate or another document. Then the revenue date will not be disputed.
2. The figures in the three documents should match. The gross weight and invoice value in the waybill and the data in the invoice and the CCD must agree with each other. Article 18 requires this information in the carrier's documents as well.
3. The copy with the border mark. Agree in the contract with the carrier or forwarder how it will be delivered to you. This copy is needed for 0% VAT (Article 261, item 3) and shows the date the border was crossed (Article 242).
4. Make two lists at month-end. First: shipments whose revenue has been recorded but which have not yet crossed the border. Second: shipments that have crossed the border but whose document has not yet reached you. Both are needed when reconciling the amount in the VAT return with the revenue in the books.
5. Check the permit in advance. If the goods are of a type that requires a permit, make sure before loading that the document is visible in the customs information system (Article 31).