VATcodexEU VAT case law · Court of Justice and General Court

Article 32 Directive 2006/112/EC

Supply of goods with transport

Title V · Place of taxable transactions › Chapter 1 · Place of supply of goods › Section 2 · Supply of goods with transport

Open in the compendium9 cases ↓

Text of Article 32

Where goods are dispatched or transported by the supplier, or by the customer, or by a third person, the place of supply shall be deemed to be the place where the goods are located at the time when dispatch or transport of the goods to the customer begins.

However, if dispatch or transport of the goods begins in a third territory or third country, both the place of supply by the importer designated or recognised under Article 201 as liable for payment of VAT and the place of any subsequent supply shall be deemed to be within the Member State of importation of the goods.

Consolidated version on EUR-Lex (CELEX 02006L0112-20250414). © European Union. Only the Official Journal is authentic.

Case law on Article 32: 9 cases

Judgments, orders and Advocate General opinions of the Court of Justice and the General Court that cite Article 32 of Directive 2006/112/EC, most recent first.

  1. C-405/24 L (Petits envois non commerciaux) Judgment · 8 May 2025 · Poland
  2. C-108/19 Krakvet sp. z o.o. sp.k Order · 14 January 2021 · Romania
  3. C-276/18 KrakVet Marek Batko Judgment · 18 June 2020 · Hungary
  4. C-401/18 Herst Opinion · 3 October 2019 · Czechia
  5. C-273/18 Kuršu zeme Judgment · 10 July 2019 · Latvia
  6. C-647/17 Srf konsulterna Judgment · 13 March 2019 · Sweden
  7. C-414/17 AREX CZ Opinion · 25 July 2018 · Czechia
  8. C-628/16 Kreuzmayr Judgment · 21 February 2018 · Austria
  9. C-386/16 Toridas Judgment · 26 July 2017 · Lithuania

VAT Committee guidelines on Article 32: 4

Not binding. Positions agreed in the VAT Committee set up under Article 398 of Directive 2006/112/EC and published by the Commission.

Commission explanatory notes on Article 32

Not binding. Guidance published by the Commission (DG TAXUD).

Explanatory Notes on the VAT e-commerce rules

Import One Stop Shop and deemed supplier rules, revised text applicable from 01-01-2027

Official PDF on europa.eu ↗