Article 31 Directive 2006/112/EC
Supply of goods without transport
Title V · Place of taxable transactions › Chapter 1 · Place of supply of goods › Section 1 · Supply of goods without transport
Open in the compendium12 cases ↓
Text of Article 31
Where goods are not dispatched or transported, the place of supply shall be deemed to be the place where the goods are located at the time when the supply takes place.
Consolidated version on EUR-Lex (CELEX 02006L0112-20250414). © European Union. Only the Official Journal is authentic.
Case law on Article 31: 12 cases
Judgments, orders and Advocate General opinions of the Court of Justice and the General Court that cite Article 31 of Directive 2006/112/EC, most recent first.
- C-234/24 Brose Prievidza Opinion · 22 May 2025 · Bulgaria
- C-83/23 H GmbH (Direct right to a refund of VAT) Judgment · 5 September 2024 · Germany
- C-703/19 Dyrektor Izby Administracji Skarbowej w Katowicach Opinion · 12 November 2020 · Poland
- C-605/12 Welmory Opinion · 15 May 2014 · Poland
- C-189/11 Commission v Spain Opinion · 6 June 2013 · Czechia, Spain, Finland, France, Greece, Italy, Poland, Portugal
- C-193/11 Commission v Poland Opinion · 6 June 2013
- C-236/11 Commission v Italy Opinion · 6 June 2013
- C-269/11 Commission v Czech Republic Opinion · 6 June 2013
- C-293/11 Commission v Greece Opinion · 6 June 2013
- C-296/11 Commission v France Opinion · 6 June 2013
- C-309/11 Commission v Finland Opinion · 6 June 2013
- C-450/11 Commission v Portugal Opinion · 6 June 2013
VAT Committee guidelines on Article 31: 5
Not binding. Positions agreed in the VAT Committee set up under Article 398 of Directive 2006/112/EC and published by the Commission.
- Meeting 125 · 18 November 2024 · document 7.1. Article 31 – CJEU Case C-68/23 Finanzamt O (Bons à usage unique)
- Meeting 060 · 2000-03-20-21 · document 4.2 Article 8(1)(b)* – nature of transaction – tiling, papering and parqueting carried out on immovable property – installation or not – place of taxation – implications in terms of intra-EU transactions
- Meeting 058 · 23 June 1999 · document II.6.1 Article 8(1)(b)* – nature of supply – assembly of machine – parts provided by the supplier or by the customer – following requirements of the customer – possible dispatch or transport – place of taxation
- Meeting 057 · 1998-12-16-17 · document 8.1 [2a] Article 8(1)* – special scheme – investment gold – place of supply – services not covered
- Meeting 052 · 1997-05-28-29 · document II.5.1 Article 8(1)(b)* – nature of supply – construction of buildings – option to regard as supply of goods – place of taxation where work is carried out – dispatch or transport of materials – liability and identification
Commission explanatory notes on Article 31
Not binding. Guidance published by the Commission (DG TAXUD).
Explanatory Notes on services connected with immovable property
Place of supply rules in force since 2017 (Implementing Regulation (EU) No 1042/2013)
- 2.4.15.1 Does Article 31a(2)(n) apply to remotely provided services? (p. 43) 226. Modern technologies can allow specialised businesses to provide, for example, part or all of their inspection or supervision services remotely (i.e. without being physically present at the place where the machines or equipment are located). Since the nature of the service is the same regardless of the technical me
Explanatory Notes on the VAT e-commerce rules
Import One Stop Shop and deemed supplier rules, revised text applicable from 01-01-2027
- 5.2 DEEMED SUPPLIER FACILITATING DISTANCE SALES OF IMPORTED GOODS (p. 95) In Scenarios 3a-3c and 4a-4b, the goods are always dispatched from a third territory or a third country to a customer in an EU Member State. The scenarios aim to briefly describe the VAT and customs implications when the electronic interface (as deemed supplier) registers in the IOSS or when it does not register in the
- 5.1 DEEMED SUPPLIER FACILITATING SUPPLIES OF GOODS WITHIN THE EU (p. 88) For Scenarios 1a, 1b and 1c and Scenarios 2a, 2b and 2c, the goods are either EU goods or goods already in free circulation in the EU. For the application of Article 14a(2), it is possible that goods were imported from a third country by the underlying supplier at a previous stage (separate transaction). If the underly
- 2.1.1 Relevant provisions (p. 14) The relevant provisions can be found in the VAT Directive and in the VAT Implementing Regulation. VAT Directive VAT Implementing Regulation • Article 14, Article 14a • Article 5b • Article 31 – 33 • Article 5c • Article 36b • Article 5d • Article 66a • Article 41a • Article 136a • Article 54b • Article 169 • Article 54