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Ruling: Sale of CO₂ credits – reverse payment obligation

Asker enters into climate agreements on CO₂ compensation with Danish companies.

The questioner would like to confirm that the service subject to VAT, which is delivered in accordance with the climate agreement on CO₂ compensation, is an advisory service that has a place of delivery in Uganda, as it is believed that the advisory service is primarily used in Uganda. Alternatively, the Questioner would like confirmation that the supply subject to VAT consists of the supply of CO₂ credits that are covered by provisions on reverse payment obligations.

Pursuant to the climate agreement, an agreement is entered into for the delivery of a total amount of CO₂ compensation for a given period in return for payment of an amount set in the agreement as the price per tonnes of CO₂. Furthermore, it appears that the Questioner delivers CO 2 credits when it fulfills its part of the purchase agreement. The Tax Council can thus confirm that the supply subject to VAT consists of the supply of CO₂ credits that have a place of delivery in Denmark and are covered by the provisions on reverse payment obligations.

Source: skat.dk

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