In the case of deliveries of goods in several stages with only one transport, it must initially be decided to which of the deliveries the transport is to be attributed in order to be able to determine whether a delivery has been made within the country.
The Swedish Tax Agency considers that a transport in the case of deliveries in several stages should be attributed to the delivery where the seller responsible for the transport out of the EU is located. The exception to this shall be if the buyer is a taxable person who is not established in this country and he is responsible for the transport. In such a case, the transport must be attributed to the transaction in which the taxable person who is not established in this country is the buyer. Being responsible for a transport means that you take care of the transport either by hiring a forwarder or an independent freight forwarder who carries out the transport out of the EU or transports the goods out of the EU yourself.
Only the delivery to which the transport out of the EU is attributed can be such export that is covered by the exemption from tax liability in ch. 10. Section 64 of the Value Added Tax Act (2023:200), ML.
This position replaces the position “Export in case of turnover in several stages with only one transport of the goods out of the EU, VAT” dated January 18, 2022, dnr 8-1428838. The new position has been drawn up in connection with ML and the position must be applied from 1 July 2023, i.e. when ML comes into force. For time before 1 July 2023, the replaced position must still be applied. The position statement clarifies how taxable transactions in several stages with only one transport of the goods out of the EU are to be assessed. The position implies a changed interpretation in such a way that only the delivery to which the transport is attributed can be covered by exemption from tax liability.
Source: www4.skatteverket.se
