Article 47 Directive 2006/112/EC

Particular provisions

Title V · Place of taxable transactions › Chapter 3 · Place of supply of services › Section 3 · Particular provisions

Open in the compendium16 cases ↓

Text of Article 47

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

Case law on Article 47: 16 cases

Judgments, orders and Advocate General opinions of the Court of Justice and the General Court that cite Article 47 of Directive 2006/112/EC, most recent first.

1. C-565/24 P-GmbH & Co. KG (Coffee trips) Opinion · 27 November 2025
2. C-501/24 Klinka-Geo Trans Order · 2 May 2025 · Hungary
3. C-277/24 Adjak Judgment · 27 February 2025 · Poland
4. C-243/23 Drebers Opinion · 6 June 2024 · Belgium
5. C-746/22 Slovenské Energetické Strojárne Judgment · 16 May 2024 · Hungary
6. C-97/21 MV - 98 Judgment · 4 May 2023 · Bulgaria
7. C-512/21 Aquila Part Prod Com Judgment · 1 December 2022 · Hungary
8. C-931/19 Titanium Judgment · 3 June 2021 · Austria
9. C-299/20 Icade Promotion Opinion · 20 May 2021 · France
10. C-215/19 Veronsaajien oikeudenvalvontayksikkö (Computing centre services) Judgment · 2 July 2020 · Finland
11. C-189/18 Glencore Agriculture Hungary Judgment · 16 October 2019
12. C-543/14 Ordre des barreaux francophones et germanophone and Others Judgment · 28 July 2016 · Belgium
13. C-516/14 Barlis 06 - Investimentos Imobiliários e Turísticos Opinion · 18 February 2016 · Portugal
14. C-155/12 RR Donnelley Global Turnkey Solutions Poland Judgment · 27 June 2013 · Poland
15. C-270/09 MacDonald Resorts Opinion · 7 September 2010 · United Kingdom
16. C-95/07 Ecotrade Opinion · 13 March 2008 · Italy

VAT Committee guidelines on Article 47: 14

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 47 – CJEU Case C-68/23 Finanzamt O (Bons à usage unique)
• Meeting 109 · 1 December 2017 · document 5.3. Article 47 – VAT treatment of services in relation to waterways
• Meeting 093 · 1 July 2011 · document 5.2 Article 47 – guidance on the scope of the rule governing services connected with immovable property
• Meeting 089 · 30 September 2009 · document 5.1 Article 47 – follow-up to VAT Package – services supplied by intermediaries – arranging of hotel accommodation – immovable property
• Meeting 083 · 2008-02-28-29 · document 4.4 Article 45 – services connected with immovable property – legal services – legal or physical alteration of property
• Meeting 060 · 2000-03-20-21 · document 4.2 Article 9(2)(a)* – 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 052 · 1997-05-28-29 · document II.5.4 · overtaken Article 9(2)(a)* – single service – fairs and exhibitions – package of services comprising various components – taxation where fair or exhibition is located
• Meeting 023 · 1988-01-12-13 · document b) · overtaken Article 9(2)(a)* – special scheme – scope – established within or outside the EU – travel agent – supplying own services – providing camping facilities and educational courses
• Meeting 017 · 1984-07-04-05 · document II.e) · overtaken Article 9(2)(a)* – place of supply – services supplied by independent experts – insurance loss adjustment – immovable property – movable tangible property – intangible property
• Meeting 016 · 1983-11-30 1983-12-01 · document II.d) · overtaken Article 9(2)(a)* – place of supply – owner letting holiday home – travel agent acting as intermediary against commission – scope of travel agent scheme
• Meeting 015 · 1982-12-08-09 · document I.d) · overtaken Article 9(2)(c)* – place of supply – services supplied by organisers of fairs and exhibitions
• Meeting 014 · 1982-06-23-24 · document d) · overtaken Article 9(1)* – place of supply – hotel and restaurant services – customers established in other countries – no exemption available
• Meeting 010 · 1980-10-23-24 · document I.d) · overtaken Article 9(2)(a)* – place of supply – types of services concerned – supplier established abroad – transfer of liability
• Meeting 005 · 1979-06-14-15 · document II.4. Article 9* – supply of service – hiring stands at exhibitions

Commission explanatory notes on Article 47

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)

• 2.2.4 What is covered by Article 13b(d)? (p. 22) 95. According to this provision, any item, equipment or machine which is permanently installed in a building or construction is deemed to be immovable property when it cannot be moved without destroying or altering the building or construction. 96. This provision refers specifically to equipment and machine but any oth
• 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
• 2.4.3.1 Which services enter the scope of Article 31a(2)(b)? (p. 30) 151. Article 31a(2)(b) provides that on-site supervision and security services shall be regarded as services connected with immovable property. 152. When initially discussed in the VAT Committee in 2011, on-site supervision was pointed out as an example of services provided in the framework of the preparation and coord
• 2.3.2 How should the ‘sufficiently direct connection’ be assessed? (p. 27) 131. It must be recalled that the rule provided for under Article 47 of the VAT Directive is a particular rule and not an exception to the general rules of Articles 44 and 45. It should be applied based on an objective assessment of the conditions provided under the VAT Directive and the VAT Implementing Regulation32 (
• 2.4.8 Valuation services (Article 31a(2)(g)) (p. 35) Article 31a(2)(g) the valuation of immovable property, including where such service is needed for insurance purposes, to determine the value of a property as collateral for a loan or to assess risk and damages in disputes; 2.4.8.1. Which services consisting in valuation of immovable property are covered by Article 31a(
• 2.4.18 Legal services (Article 31a(2)(q) and Article 31a(3)(h)) (p. 46) Article 31a(2)(q) legal services relating to the transfer of a title to immovable property, to the establishment or transfer of certain interests in immovable property or rights in rem over immovable property (whether or not treated as tangible property), such as notary work, or to the drawing up of a contract to sell
• 2.4.11.2 Which are the limits to the scope of Article 31a(2)(j)? (p. 39) 208. The scope of this provision is broad but remains strictly limited by the condition of the existence of a ‘sufficiently direct connection’ between the service and the immovable property. While examples such as mooring, anchorage, docking, provision of berth services46 in port or airport premises, provision of right
• 2.4.2 Drawing up of plans (Article 31a(2)(a) and Article 31a(3)(a)) (p. 29) Article 31a(2)(a) the drawing up of plans for a building or parts of a building designated for a particular plot of land regardless of whether or not the building is erected; Article 31a(3)(a) the drawing up of plans for a building or parts of a building if not designated for a particular plot of land; 2.4.2.1. What is
• 2.4.20.1 What is the scope of application of Article 31a(3)(e)? (p. 50) 274. Article 31a(3)(e) covers the situations where the provision of a stand location at a fair or exhibition site is accompanied by other related services and defines them as not connected with immovable property. © European Union, 2015 26/10/2015 Page 50 of 55 275. Even if the provision of a stand location is accompan
• 2.4.7.1 What is the purpose of Article 31a(2)(f)? (p. 34) 178. Article 47 of the VAT Directive defines the place of supply of services connected with immovable property and makes explicit reference to the services of experts. Like valuation services, surveying and assessment of the risk and integrity of immovable property constitute such expert services and must be taxed acco
• 2.1 General approach to Articles 13b and 31a (p. 15) 35. Part 2 of these explanatory notes provides clarification on the application of the provisions of the VAT Implementing Regulation aiming at determining the place of supply of services connected with immovable property. 36. When services qualify as services connected with immovable property, the place of their supply
• 2.4.1 Is the list of Article 31a(2) indicative or exhaustive? (p. 29) 145. The list under Article 31a(2) is purely indicative and provides, as indicated by its wording (‘in particular’), examples of specific services which the EU legislator has considered as being connected with immovable property in the sense of Article 47 of the VAT Directive. By doing so, it provides legal certainty i

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Explanatory Notes on the VAT e-commerce rules

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

• 3.2.6 Place of supply (p. 42) The place of supply of TBE services made by a taxable person (the supplier) established in a Member State to a non-taxable person (the customer) in another Member State is in the Member State where the customer resides. The place of supply of intra-Community distance sales of goods shall be deemed to be the place where

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