The place of VAT taxation on complex storage services – EU Court of Justice ruling

In general the place of taxation of the service shall be determined on basis of the place where the customer is established or has a fixed establishment. There are numerous exceptions from this rule though. Inter alia the services connected with the immovable property which are taxed at the location of the immovable property. How to determine the place of VAT taxation for storage services?

Recently the EU Court of Justice has made a decision regarding that issue.


The Court (First Chamber) hereby ruled:

Article 47 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, as amended by Council Directive 2008/8/EC of 12 February 2008, must be interpreted as meaning that the supply of a complex storage service, comprising admission of goods to a warehouse, placing them on the appropriate storage shelves, storing them, packaging them, issuing them, unloading and loading them, comes within the scope of that article only if the storage constitutes the principal service of a single transaction and only if the recipients of that service are given a right to use all or part of expressly specific immovable property.