Proforma invoice accepted at export where sales document comes later

Exporters that only know the buyer and price after the goods have left Norway get a clarified route to VAT-free export.Skatteetaten In the statement «Krav til dokumentasjon ved utførsel av varer» (Publisert: 16.10.2026Skatteetaten; Avgitt 16.10.2026Skatteetaten), Skattedirektoratet sets out when a sales document may be issued without the export declaration and export certificate in hand, and when a provisional invoice (proformafaktura) must be presented at the customs export procedure instead.

The background is a seeming clash between rulebooks. Merverdiavgiftsforskriften § 6-21-1, read with bokføringsforskriften § 5-2-6, assumes the VAT exemption is documented with an export declaration and export certificate before a sales document without VAT may be issued. Vareførselsforskriften § 5-9-2 on the utførsel procedure, by contrast, appears to assume a sales document (faktura) already exists at the time of export. Taken literally, no complete sales document could ever serve as the basis for the export procedure, since the declaration and certificate would always have to come first.

Skattedirektoratet resolves this in dialogue with Tolletaten, whose reply letter of 20 August 2025 is quoted: the timing of the sales document under the bookkeeping rules determines when a proforma invoice is acceptable, destination-country requirements for customs-value documentation matter too, and proforma invoices are already in extensive use for seafood exports — especially fresh fish, which is sold and traded in transit so that neither price nor buyer is known at export, with the sales document only issuable after repacking, for example at a warehouse in Denmark, often the day after the fish left Norway by truck.

The conclusions. A sales document may be issued before the declaration and certificate exist where this happens in close connection with the time of export.Skatteetaten Where the sales document is issued after the time of export, a provisional invoice must be issued in connection with the export.Skatteetaten Where goods are first sold in transit abroad, so buyer and price are unknown at export and can appear in neither the provisional invoice nor the export declaration, the provisional invoice is issued without that informationSkatteetaten and serves as the basis for obtaining the declaration and certificateSkatteetaten; the declaration must later be corrected so it matches the final sales documentSkatteetaten, and the corrected declaration is kept as part of the exemption documentation. In every case the sales document, the declaration and the export certificate must exist as documentation for the zero-rated turnover reported in the VAT returnSkatteetaten, and be retained under the bookkeeping rules.

The underlying duties are unchanged: export of goods out of the VAT area is exempt under mval. § 6-21, documented with sales document, declaration and export certificate per vareførselsforskriften § 5-9-2 third and fourth paragraphs; at the utførsel procedure all documents issued in connection with the export, including any sales invoice, must be presented, though with electronic declaration no supporting documents need be presented unless customs asks. Legal basis is mval. § 6-21 with merverdiavgiftsforskriften § 6-21-1, bokføringsforskriften chapter 5-2 and vareførselsforskriften § 5-9-2; the statement was issued by Skattedirektoratet on 16 October 2026Skatteetaten.