COUNCIL IMPLEMENTING DECISION (EU) 2019/2244 of 16 December 2019 authorising Spain and France to apply a special measure derogating from Article 5 of Directive 2006/112/EC on the common system of value added tax,
France and Spain are constructing high-voltage direct current links between Cubnezais (France) and Gatica (Spain). The project costs are borne equally by the two countries. In order to reduce the complications relating to the tax implications of the project, all transactions relating to the construction will be treated equally, i.e. 50% are deemed to take place on French territory and 50% on Spanish territory.
Source European Commission
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