VAT group counts as importer when a member declares the goods

Skatteverket added a clarification dated 9 September 2026 to its rättslig vägledning page on import (Import)Skatteverket, settling how a member of a VAT group (mervärdesskattegrupp) acts in the customs declaration when goods are imported into Sweden and Skatteverket is the taxing authority.

A member of a VAT-registered VAT group that names itself as declarant in the customs declaration, or is named as the person represented by an indirect customs agent, is deemed registered for VAT for the purposes of Chapter 2, Section 2 of the Customs Act (tullagen)Skatteverket — the provision that identifies the declarant (see prop. 2013/14:16 p. 19). Such a member may therefore be regarded as entitled to represent the group and to complete formalities vis-à-vis Tullverket. Where the member names itself as declarant, or is named as the person the indirect agent represents, the VAT-registered VAT group is deemed the importer (importör) and the member its agent under Chapter 16, Section 20 of the VAT Act (mervärdesskattelagen)Skatteverket.

The practical effect is on who bears the import VAT. Skatteverket starts from the position that a customs debtor who is not itself the declarant for a given import acts as agent for the importer — the VAT-registered declarant or, following this clarification, the VAT-registered VAT groupSkatteverket — and that the importer is the party liable to paySkatteverket. If the importer does not report the VAT, the customs debtor must, at Skatteverket's request, be able to show that it acted as the importer's agent under an oral or written mandateSkatteverket; if it cannot, the customs debtor itself is liable for the VATSkatteverket. The operative rule paragraph's parenthetical was widened accordingly to read "den mervärdesskatteregistrerade deklaranten eller den mervärdesskatteregistrerade mervärdesskattegruppen"Skatteverket.

The clarification sits in the general framework that, where Skatteverket is the taxing authority and a customs debtor acts as agent, only the principal is liable for import VAT (Chapter 16, Section 20 of the VAT Act), and that the agent provision can only apply where the agent holds a mandate to represent an importer that is VAT-registered in Sweden at the time of Tullverket's decision establishing customs duty. For VAT groups importing through a member or an indirect agent, the new text removes doubt about which entity counts as the importer. Legal basis: 2 kap. 2 § tullagen and 16 kap. 20 § mervärdesskattelagen (2023:200), as applied in Skatteverket's rättslig vägledning on import, with background in prop. 2013/14:16 on the changed handling of VAT on imports.