Tax Authority Penalties

The following table contains, by means of various use cases, some reasons for incurring penalties in VAT Services on Amazon subscription countries, details on the potential penalty amount and late payment interest rates, if any. The application of penalties in case of infractions can be a complex and subjective legal matter. Therefore, this table cannot be seen as a complete overview of the penalties or policies from the tax authority.

Note: Details under the section “Tax Authority Penalties” have been provided by a third-party tax provider, Avalara, and should be read as general guidance only. Tax authorities will make assessments on penalties on a case-by-case basis. Information on this page does not constitute tax, legal or other professional advice, and must not be used as such.

Country	Causes	Amounts	Interest
UK	Late VAT filing and/or late VAT payment	Penalties increase with each late payment. The first late payment will incur no penalties, after which: Annual turnover is less than GBP 150,000.00: 2^nd late payment = no penalty 3^rd late payment = 2% of VAT liability (penalty waived if less than GBP 400.00) 4^th late payment = 5% of VAT liability (penalty waived if less than GBP 400.00) 5^th late payment = 10% of VAT liability or GBP 30.00, whichever is more 6^th and subsequent late payments = 15% of VAT liability or GBP 30.00, whichever is more Annual turnover is GBP 150,000.00 or more: 2^nd late payment = 2% of VAT liability (penalty waived if less than GBP 400.00) 3^rd late payment = 5% of VAT liability (penalty waived if less than GBP 400.00) 4^th late payment = 10% of VAT liability or GBP 30.00, whichever is more 5^th and subsequent late payments = 15% of VAT liability or GBP 30.00, whichever is more
	VAT return contains careless or deliberate inaccuracy	100% of any tax under-stated or over-claimed
	Tax authorities’ assessment is too low and you don’t inform them it is wrong within 30 days	30% of assessment
Germany	Late VAT filing	1% to 10% of VAT liability
	Late VAT payment	1% per month on every full EUR 50.00 unpaid; e.g. VAT liability = EUR 183.00; payment delay= one month; penalty = 1% of 150 = EUR 15.00
	Unpaid VAT discovered in Audit	Interest payment starting 15 months after payable VAT deadline; E.g. If payable VAT deadline is 10 Jan 2014; interest starts in April 2016	6% per annum
France	Late VAT filing	0-30 days – Up to 10% Return not submitted within 30 days after receiving a notification from the Tax Authorities – Up to 40% Suspicion of fraud – Up to 80%	2.4% per annum
	Late VAT payment	0-30 days – Up to 10% Return is not submitted within 30 days after receiving a notification from the Tax Authorities – Up to 40% Suspicion of fraud – Up to 80%	2.4% per annum
	Unpaid VAT discovered in Audit	Decided on a case-by-case basis	Decided on a case-by-case basis
Spain	Late VAT registration	EUR 400.00
	Late VAT filing	If notified by the Tax Authorities and tax payment due: 50-150% of the VAT payments due If notified by the Tax Authorities and no VAT payment due: EUR 200 If voluntary disclosure and no VAT payment due: EUR 100, EUR 200 If voluntary disclosure and tax payment due: 5-25% of the VAT payments due (25% reduction if paid within deadlines)
	Incomplete returns	EUR 300.00-EUR 20,000.00; Calculated with EUR 20.00 per incomplete information
	Late VAT payment	0-3 months – 5% of VAT payment due; 3-6 months – 10% of VAT payment due 6-12 months – 15% of VAT payment due After 12 months – 20%	After one year – 3.75% per annum
	Unpaid VAT discovered in Audit	50-150% of the VAT payment due
Poland	Late VAT registration	PLN 93.60 to PLN 18,720.00
	Late VAT filing	PLN 93.60 to PLN 18,720.00
	Late VAT payment	Interest on payment due	8% per annum
	Unpaid VAT discovered in Audit	Decided on a case-by-case basis	8% per annum
Czech Republic	Late VAT filing	For each day of delay: 5% of VAT payment due
	Late VAT payment	Interest on payment due	15% + <Repo rate in the applicable country for every calendar half year>
	Unpaid VAT discovered in Audit	20% of the VAT payment due

For Italy		Reduced penalties (applied to base penalty)	Time frame
Reason	Penalties	Reduced penalties (applied to base penalty)	Time frame
Late payments	30%	1/10 + (1/15 for each day of delay)	Within 14 days of the violation
		1/10	Between 15 and 30 days from the violation
		1/9	Between 31 and 90 days from the violation or from the deadline of Annual Return
		1/8	Within one year of the violation or within the deadline of Annual Return relating to FY in which the violation occurred
		1/7	Within two years of the violation or within the deadline of Annual Return relating to FY following the year in which the violation occurred
		1/6	After two years of the violation or after the deadline of Annual Return relating to FY following the year in which the violation occurred
		1/5	After having received the “verbale di constatazione - PVC” (official notice)
Incorrect Annual Returns	90% to 180% of VAT payment due	1/9	Within 90 days of the violation or of the Annual Return deadline
Incorrect Annual Returns	90% to 180% of VAT payment due	1/8	Within one year of the violation or within the deadline of Annual Return relating to FY in which the violation occurred
Communications not filed (Annual Communication, ANR or black list)	EUR 516.00 to EUR 2,065.00	1/7	Within two years of the violation or within the deadline of Annual Return relating to FY following the year in which the violation occurred
	EUR 516.00 to EUR 2,065.00	1/6	After two years of the violation or after the deadline of Annual Return relating to FY following the year in which the violation occurred
Annual Returns not filed	120% to 240% of the VAT payment due; minimum EUR 258.00	50%; minimum EUR 200.00	Within 1 year of the Annual Return deadline
Accounting violations	90% to 180% of the VAT payment due; minimum EUR 500.00 EUR 258.00 to EUR 2,000.00 if the VAT payment has been made 5% to 10% of the VAT payment due if the transactions are not subject to VAT	1/9	Within 90 days of the violation
Not issuing invoices or receipts	150% of the VAT payment due; minimum of EUR 500.00	1/9	Within 90 days of the violation

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