From 1 January 2027 import VAT can be offset against an overpayment on sales for certain categories: the Regulation has been registered
Under the Regulation approved by a decision of the Ministry of Economy and Finance and the Tax Committee and registered by the Ministry of Justice as No. 3966, for four categories of taxpayers VAT payable at customs on imports can be settled from an overpayment held with the tax authority; the rule takes effect on 1 January 2027.
The official document: the decision of the Ministry of Economy and Finance of 20 October 2026 No. 404 and of the Tax Committee of 13 October 2026 No. 2026-26 (agreed with the Chamber of Commerce and Industry). Registered by the Ministry of Justice on 31 October 2026 under No. 3966 (QMMB 10/26/3966/1089-son). The Regulation attached to it sets the procedure for offsetting VAT payable on imports against VAT paid on sales of goods (services). The decision and the Regulation take effect on 1 January 2027.
What does it mean?
«Offsetting» under the Regulation means that a taxpayer settles VAT payable at customs on imported goods from its overpayment of VAT paid on sales. In other words, import VAT can be covered not by a separate payment but from the overpayment on the personal account with the tax authority.
Who does it apply to?
According to the Regulation, offsetting applies to:
| No. | Category |
|---|---|
| 1 | Enterprises administered by the interregional tax inspectorate for large taxpayers |
| 2 | Electrical engineering enterprises importing raw materials and components for production needs |
| 3 | Business entities with a stability rating of «BBB» or higher (except state enterprises and legal entities with a state share of 50% or more in the charter capital) |
| 4 | Participants in foreign economic activity with a low risk level and an active VAT certificate |
How does it work?
- When filing the customs cargo declaration (BYD), the taxpayer enters the code «VZ» in graph 47, column «TU», thereby notifying customs of the VAT offset.
- After the BYD arrives, the Customs Committee sends the Tax Committee a request in real time (Appendix 1 to the Regulation) to confirm that the personal account holds the required overpayment.
- The Tax Committee automatically checks the personal account and sends the Customs Committee the overpayment amount that can be accepted for the offset.
- An offset act is formed automatically in the information system for the confirmed amount (Appendix 2 to the Regulation).
- The Customs Committee reflects the amount in the act on the taxpayer's personal account with customs and takes steps to process the BYD.
- Movement of funds: if the overpayment arose from a «negative difference», from republican budget funds through the treasury account for refunding negative VAT differences; if it arose from VAT paid, by reducing current VAT receipts. The Customs Committee then transfers the funds to the State Budget within the periods set by the Customs Code, and the tax authority reduces the overpayment on the personal account by the offset amount.
What documents are drawn up?
| Document | At what stage | Place in the Regulation |
|---|---|---|
| Customs cargo declaration (BYD), code «VZ» in graph 47, column «TU» | Notifying of the offset | item 4 |
| Request (from the Customs Committee to the Tax Committee) | Confirming the overpayment exists | item 5, Appendix 1 |
| Offset act | Recording the accepted amount | item 7, Appendix 2 |
| Conclusion (on offsetting the overpayment against tax debt, including debt with a changed payment date; the Tax Committee forms it automatically) | Settlement of tax debt | item 11, sub-item 1) |
| Electronic payment order (to transfer the VAT amount in the act to the Customs Committee) | Transferring the money | item 11, sub-item 1) |
When is offsetting not done?
- Where there is an amount of tax risk and/or tax debt identified by the tax authorities' information systems (including tax debt with a changed payment date), to the extent of those amounts; the tax debts of large taxpayers with a changed payment date are excepted.
- During the period when tax control measures are being carried out against the taxpayer.
If such debts exist on the date of the offset, the offset is made for the remaining part of the overpayment after the debts have been reduced (item 9 of the Regulation).
What if the amount in the BYD is reduced?
If, after the request is sent, the VAT amount calculated in the BYD is reduced, the VAT amounts transferred in excess to the Customs Committee's personal treasury account are transferred within one working day to the relevant personal treasury account for State Budget revenues (item 12). For amounts offset before the Regulation takes effect, the Customs Committee also provides information to the Tax Committee.
What is not known?
- The Regulation does not say that a separate application or permission is required besides the code «VZ»; nor does it say how belonging to one of the four categories is confirmed.
- The dates of the decision and registration are in the document, but the date of the Telegram post is not given; on our site the news item was published on 13 November 2026.
Practical advice
A company planning to settle import VAT in this way may want to check, before 1 January 2027, whether it has an overpayment on its VAT personal account with the tax authority, whether it falls into one of the four categories of the Regulation (rating, VAT certificate and so on) and to bear in mind that with a tax debt the offset is not made to the extent of the debt (item 9), and that no offset is made during a period of tax control.
This news item is a summary of the official document. For the exact conditions, see the full text of the Regulation.
Official source
For information only; check the official text at the source.