IE599 missing? Alternative evidence of export outside the EU – rules and CJEU case law (2026)

IE599 message is a standard proof confirming export of goods outside the EU, entitling to 0% VAT rate. However, in practice IE599 does not always arrive on time – due to system delays, technical errors or border issues.

Does the absence of IE599 automatically result in the loss of the 0% rate? Not necessarily — but there is no automatic right to 0% on the strength of any documents either. The Polish VAT Act requires a document confirming export, and EU customs law provides a procedure in which the customs office of export certifies the exit of the goods on the basis of alternative evidence. This article sets out the rules, that procedure and the CJEU case law — with case numbers and the content of the operative parts.

Naming: in the current AES/ECS2 PLUS system the export confirmation is message CC599C; in practice it is still called “IE599” (the name from the previous version of the system). According to the PUESC user guide, CC599C is the customs document confirming, also for tax purposes, that the goods were exported outside the EU. It is a message of the EU export system — it is sent by the Polish office of export after information from the office of exit in the EU. It is not issued by the UK customs system.

What the Polish VAT Act says (Article 41(6)–(9))

• paragraph 6 — the 0% rate applies if, before the deadline for filing the VAT return for the period, the taxpayer has received a document confirming that the goods left the EU;
• paragraph 6a — that document is in particular an electronic document from the export declaration system (or a printout certified by the customs authority), a document from that system received outside it if its authenticity is ensured, or a paper export declaration certified by the customs authority;
• paragraphs 7–8 — if the document has not arrived in time and the taxpayer holds a customs document confirming the export procedure, the supply is reported in the next period at 0%, provided the document is received before the return deadline for that period; otherwise the domestic rate applies;
• paragraph 9 — a document received later entitles the taxpayer to correct output VAT in the period in which it was received.

Source: Polish VAT Act, consolidated text Dz.U. 2025 item 775. In practice: a late IE599 does not take the 0% rate away for good, because paragraphs 7 and 9 let you recover it. A CMR or correspondence submitted to the tax office is not, however, listed in paragraph 6a — the safe route is to obtain certification of exit from the customs office of export.

When IE599 does not arrive: the procedure in Articles 334–335 of Regulation 2015/2447

EU customs law sets out a formal route for cases where the customs office of export has not been informed that the goods left the EU (Implementing Regulation (EU) 2015/2447):

1. After 90 days from the release of the goods for export, the customs office of export may ask the declarant for the date on which, and the customs office of exit from which, the goods left the EU (Article 335(1)). The declarant may also provide this information on its own initiative (paragraph 2). In the Polish AES system the enquiry is message CC582C and the reply is CC583C, which can include details of alternative documents (PUESC AES/ECS2 PLUS user guide).
2. At the declarant's request, the office of export asks the office of exit, which has 10 days to reply (paragraph 3).
3. If the office of exit does not reply, the declarant may provide evidence that the goods left the customs territory of the Union (paragraph 4), in particular: a copy of the delivery note signed or authenticated by the consignee outside the EU, proof of payment, the invoice, the delivery note, a document signed or authenticated by the operator that took the goods out of the EU, or a document processed by the customs authority of a Member State or a third country (for example a UK import declaration in CDS).
4. If the office of export considers the evidence sufficient, it certifies the exit of the goods (Article 334(1)(c)). The confirmation from the export system is the document referred to in Article 41(6a) of the Polish VAT Act.

CJEU case law — what the Court actually ruled

Below are summaries of the operative parts of the judgments, with case numbers and links to the full texts. We do not quote the Court: the operative parts do not contain the sentences that are often attributed to these judgments online.

C-275/18 Milan Vinš — export outside the EU

Article 146(1)(a), read with Article 131 of the VAT Directive, precludes a national provision from making the export exemption conditional on the goods being placed under the export customs procedure, where it is established that the substantive conditions of exemption are met — in particular that the goods actually left the EU (judgment C-275/18). This is the ruling closest to the topic: proven exit counts, but the burden of proof stays with the exporter.

C-563/12 BDV Hungary Trading — time limit for export

Articles 146(1) and 131 of the VAT Directive preclude national rules under which exported goods must leave the EU within a fixed period of three months or 90 days after the supply, where merely exceeding that time limit results in the definitive loss of the exemption (judgment C-563/12). The ruling is about the export deadline, not about errors in customs documents.

C-146/05 Collée and C-273/11 Mecsek-Gabona — intra-Community supplies

Both judgments concern intra-Community supplies, not exports outside the EU. In Collée (a German car dealer) the Court held that the exemption for an intra-Community supply which actually took place cannot be refused solely because the evidence of that supply was not produced in good time (judgment C-146/05). In Mecsek-Gabona (rapeseed sold to Italy) the Court held that the exemption may be refused where the vendor failed to meet its obligations as regards evidence, or knew or should have known of the purchaser's fraud, but not solely because the purchaser's VAT number was removed from the register with retroactive effect (judgment C-273/11). They illustrate a substance-over-form approach but do not decide export cases.

What evidence to collect when IE599 is missing

• a CMR or other delivery note signed by the consignee in the UK (Article 335(4)(a) and (d));
• a document from the carrier that took the goods out of the EU (point (e));
• confirmation of UK import clearance in CDS — the MRN of the import declaration, from your client or its customs agent (point (f));
• the invoice and proof of payment (points (b) and (c));
• the export MRN and declaration status in PUESC.

These documents are submitted to the customs office of export under the Article 335 procedure, not instead of it to the tax office. Whether the 0% rate can be applied in a given period is for the tax authorities to assess — in doubtful cases consult a tax advisor or apply for an individual tax ruling.

Frequently Asked Questions (FAQ)

Does the Tax Office have to accept alternative evidence?

Not automatically. Article 41(6) and (6a) of the VAT Act require a document confirming export, primarily from the export declaration system. Alternative evidence is used to obtain certification of exit from the customs office of export (Articles 334–335 of Regulation 2015/2447). CJEU case law (C-275/18, C-563/12) protects exporters against losing the exemption for purely formal reasons where the exit of the goods is proven.

What to do if the Tax Office rejects alternative evidence?

A tax decision can be appealed under the Polish Tax Ordinance — ideally with the help of a tax advisor. In the appeal, present the certification of exit obtained under Article 335 and refer to the CJEU case law on exports (C-275/18, C-563/12).

Can I apply the 0% rate without IE599 immediately?

The Act links 0% to receiving a document confirming export before the return deadline (Article 41(6)). If you do not have it, paragraph 7 lets you report the supply in the next period and paragraph 9 lets you correct the tax once the document arrives. Applying 0% on the basis of a CMR or correspondence alone is risky — discuss it with a tax advisor.

Do alternative proofs also work when exporting to other countries (not only the UK)?

Yes. Article 41 of the VAT Act and Articles 334–335 of Regulation 2015/2447 apply to every export from the EU customs territory.

How long must I keep alternative evidence?

Documents relating to VAT settlement must be kept until the tax liability becomes time-barred (Article 112 of the Polish VAT Act). In AES the declarant should also keep the CC599C message together with the documents relating to the declaration (PUESC user guide).

How can easyclearance.pl assist?

Collecting alternative evidence

If IE599 has not arrived, our team can assist with: - Obtaining a copy of the export declaration from the PUESC system. - Contacting the customs office to clarify status. - Preparing an evidence package for the customs office of export (Article 335 of Regulation 2015/2447).

Coordination with the client in the UK

If you need confirmation of import clearance in the UK, we can: - Contact your client in the UK. - Obtain confirmation of the UK import declaration in CDS (MRN). - Confirm receipt of goods.

Documentation for your VAT settlement

Our team can assist with: - Organising the customs documents for your tax advisor. - Pointing to the provisions and CJEU rulings you can rely on. - Supplementing customs documentation in the event of an audit.

Distinction: easyclearance.pl is a customs agency based in the UK. We directly handle clearances in Great Britain. If your shipment requires customs clearance in Poland or another EU country, we coordinate the process through our network of local partners with the required customs authorisations.

Summary

Lack of IE599 does not automatically mean loss of the 0% VAT rate entitlement. Key principles:

1. Article 41(6)–(9) of the VAT Act — 0% with a document received before the return deadline; a late document lets you report the supply in the next period or correct the tax. 2. Articles 334–335 of Regulation 2015/2447 — alternative evidence goes to the customs office of export, which certifies exit. 3. Act proactively — collect evidence continuously and do not wait for the return deadline. 4. CJEU case law (C-275/18, C-563/12) protects against losing 0% for purely formal reasons, but the export must be proven.

Need help with alternative proof of export?

If you did not receive IE599 and need support preparing alternative export proofs, contact easyclearance.pl. We will assist in gathering documentation and communicating with the Tax Office.

easyclearance.pl is a customs agency based in the United Kingdom. We directly handle clearances in the UK. Customs clearances within the EU are carried out in cooperation with our network of local partners with the required customs authorisations. Contact us →

What the current official guidance means in practice

For operational work, the current procedural rules, declaration fields and relief conditions should be checked directly against the official guidance. For this topic, the core reference points are European Commission, GOV.UK / HMRC.

Official sources

• EU Commission (Customs procedures) — European Commission, 2026-03-04
• UK GOV (Importing into the UK) — GOV.UK / HMRC, 2026-03-04
• GOV.UK: Customs Declaration Service — GOV.UK / HMRC, 2026-03-04