The situation
A three-party sale from a German manufacturer via a Polish distributor to a Czech customer, with one transport
Your client, a distributor in Poznań, buys pumps from a manufacturer in Stuttgart and sells them on to a building contractor in Brno. The pumps go straight from Stuttgart to Brno on a truck booked by your client’s forwarder. The Czech customer has asked who will charge VAT, and so has the German supplier.
The rule fits on one page. The hours go on the facts: who booked and paid for the transport, which VAT number your client gave the German supplier, what the delivery terms say. Then the consequences for each leg, including whether your client needs a Czech registration, have to be written so both counterparties can follow them.
What the research has to settle
The rules behind the answer
- Only one supply in the chain moves
- Where goods pass through several sellers but travel once, the single intra-Community transport is attributed to one supply only. That supply can be exempt as an intra-Community supply. Every other supply in the chain is taxed where the goods are at that moment.
- Before or after the transport
- A supply that comes before the moving supply takes place in the country of departure, here Germany. A supply that comes after it takes place in the country of arrival, here the Czech Republic, and can bring a VAT obligation there for the seller.
- The intermediary rule in the VAT Directive
- Since 2020, where the intermediary operator arranges the transport, the Directive attributes it to the supply made to that intermediary. The exception: if the intermediary gave its supplier a VAT number of the departure country, the transport goes with the intermediary’s own onward supply.
- Who transports is a question of fact
- Where the first supplier or the final customer organises the transport, the intermediary rule does not apply and the attribution follows the facts and the Court of Justice case law. The memo should record the evidence: the transport order, the freight invoice and the agreed delivery terms.
How it runs in azta
From the question to the document
The question, as you would type it
German manufacturer sells pumps to our Polish client, which resells them to a Czech contractor. Goods go directly from Stuttgart to Brno, transport booked and paid by our client, which quoted its Polish VAT number. Which supply is the moving supply, and where is each supply taxed?
You start with
A three-party sale from a German manufacturer via a Polish distributor to a Czech customer, with one transport
- 01
Set out the chain
Describe each party, the VAT numbers used and who arranges the transport. azta searches the VAT Directive, the German, Polish and Czech VAT acts and the Court of Justice decisions on chain transactions.
Cited research· Free - 02
Read the attribution rule
Open the cited provisions in the reader, in the original language with their in-force status, and compare the Directive with each national implementation.
Atlas statute reader - 03
Follow the consequences leg by leg
Ask what follows for the onward supply to Brno: a Czech registration, or the triangulation simplification. azta answers each with the provisions cited.
Cited research· Free - 04
Write the memo
Ask for a memo with facts, attribution and consequences per supply. Edit it in Canvas and select any passage to shorten or translate it for the counterparties.
Canvas · Ask azta· Pro You send
A memo on which supply is the moving supply and where each supply is taxed
What you get
A memo on which supply is the moving supply and where each supply is taxed
Memo · draft
Stuttgart to Brno pump deliveries: attribution of the transport
Facts. The goods are dispatched once, from the manufacturer’s plant in Stuttgart directly to the customer’s site in Brno. Our client, the Poznań distributor, orders and pays for the transport and has given the manufacturer its Polish VAT number.
Attribution. Our client acts as the intermediary operator. Because it arranges the transport and has not used a German VAT number, the transport is attributed to the manufacturer’s supply to our client. That supply is the intra-Community supply, exempt in Germany, with an intra-Community acquisition in the Czech Republic.
Consequences. Our client’s onward supply to the Brno contractor takes place in the Czech Republic. Section 4 sets out whether our client must register for VAT there or can apply the triangulation simplification, and what its invoice must then state. We recommend keeping the transport order and freight invoices with this memo.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
11 minutes a month
At €160 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 43
- Capacity at your rate
- €6,912
- More memos on chain transactions a quarter
- 2.3
- Return on Pro
- 21.3×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
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What stays with you
- Establishing from the documents who actually ordered and paid for the transport.
- Agreeing the treatment with the German supplier and the Czech customer.
- The position in the memo and your signature on it.
Frequently asked questions
- Does azta cover chains with more than three parties?
- Yes. Describe each party, its VAT numbers and who arranges the transport. The same attribution rules apply, and the answer cites them for each link in the chain.
- What if the facts on transport are unclear?
- Say so in the question. azta sets out how the answer changes depending on who arranged the transport, so you can see what to confirm with the client.
- Can I see the national rule as well as the Directive?
- Yes. Each citation opens the provision in the original language with its in-force status, for the Directive and for each national VAT act.
