Legal and Compliance

What is the Reverse Charge Mechanism (RCM) in VAT?

Author: Oleksandra Butenko, Copywriter

Reviewed by: George Ploaie, Chief Operating Officer (COO)

What is the Reverse Charge Mechanism (RCM) in VAT

What is the Reverse Charge Mechanism (RCM) in VAT?

The Reverse Charge Mechanism (RCM) is an accounting rule that moves the obligation to report and pay VAT from the seller to the buyer. In standard VAT conditions, the vendor takes, charges, and collects tax from the buyer, and finally gives the revenue to the Government. However, under RCM, the taxpayer (i.e., seller) would issue to the customer or business client an invoice with 0% VAT and leave the tax declarations to the buyer’s responsibility to be declared under their local laws (e.g., the company customer should make tax filings to both output tax (the tax owed) and input tax (the tax claimed) to their own tax authorities.

Who normally charges VAT vs. who handles it under RCM?

It is called “reverse” because it flips the traditional direction of tax collection.

  • Normal VAT Flow: Seller – Charges VAT to Buyer – Remits to Government.
  • Reverse Charge Flow: Seller – Sends 0% VAT Invoice – Buyer self-accounts and reports directly to the Government.

Which transactions fall under RCM?

RCM applies to selected business-to-business (B2C) transactions to stop fraud and eliminate foreign companies from having to register for local VAT:

  • Business-to-Business (B2C) Transactions: e.g., digital services, Software as a Service (SaaS), consulting, or marketing services that are provided by a company in one country (e.g., Germany) to a company in another (e.g., France).
  • Domestic Sectors: The analysis identifies relationships between local industries and ‘Missing Trader’ fraud activity. For example, construction (e.g., a subcontractor to a main contractor), waste management/scrap metal, etc.

What are the buyer's obligations under RCM?

When a sale qualifies as RCM, you have to:

  • Determine Your VAT yourself: Based on the prevailing tax rate of the country where you are the buyer, decide the amount of VAT you will charge.
  • Declare Output Tax: You will have to enter that amount onto your local VAT return, which will represent output VAT and therefore a tax payable at the end of the tax period.
  • Claim Input VAT: If this purchase falls within the scope of fully tax-exempt business activities, the business taxpayer can also claim an input VAT to the company of the amount that they’ve declared. Upon the completion of the process, the net cash flow is frequently consistent with a zero balance.

How to configure a SaaS billing engine for RCM?

The subscription billing platform has three basic features to handle cross-border B2B sales automatically at the moment of the purchase:

  1. B2B Switch: Implementation layer of Checkout

On Checkout, add a field asking, “Are you purchasing for a business?” When this option is selected, show a field for a corporate VAT ID.

  1. Real-Time Tax ID Verification Integration: API Level

The checkout system needs to be connected via the API to connect with tax databases (for example, the EU member states, VIES service). Once a valid and active tax number is found through the verification. It means a 0% tax will be charged to the consumer in that local area, thereby changing the billing logic to remove consumer tax from the bill.

  1. Generation of Invoices That Meet Legal Requirements: Documentation Level

Make an internal change in the PDF invoice generation tool so that the legal disclaimer texts, which are necessary by law, are automatically included at the foot of the document only when a transaction falls into a category regulated by the RCM law. This is usually a clause that a company, as the buyer, was the one to validate their VAT ID, and then that the buyer has the obligation to remit VAT (also referred to as a “Reverse Charge” provision, which is usually written in detail with a clear tax code, such as Article 196 of the EU VAT Directive). ​‍​‌‍​‍‌

What are the risks of getting RCM wrong?

The approach to reverse charge can relate to financial outcomes:

  • Scenario A: You are not eligible under RCM, but you bill the client local VAT.  When a business client for RCM is charged VAT, the typical procedure does not involve filing a regular tax return to obtain a refund. Issuing a correct invoice and processing a manual refund are part of addressing the request, which often involves procedural adjustments and impacts customer experience.
  • Scenario B: VAT is not applied in situations where collection was required. The deployment of the RCM in circumstances where unregistered businesses or B2C consumers, where its particular applicability is not established, is subject to review by tax authorities. Before a business audit, the company’s responsibilities include any outstanding VAT remittance, accrued interest, and associated administrative penalties.

Conclusion

The Reverse Charge Mechanism concerns VAT, allowing businesses to charge VAT only under specific conditions, which can influence tax administration processes and foreign tax documentation for B2B entities. Even if compliant buyers have no direct financial involvement, the business is responsible for accurate record-keeping and the checkout process.

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