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European Court of Justice Opinion on Romanian VAT Place of Supply Rules

  • The European Court of Justice issued an advocate general opinion on Romanian VAT rules on the place of supply of services.
  • The case involved a Romanian group entity manufacturing and assembling automotive upholstery components for a German company within the group.
  • The Romanian National Agency for Fiscal Administration determined that the services were subject to VAT in Romania.
  • A Romanian regional court requested a preliminary ruling on multiple questions, including on place of supply.
  • The advocate general opined that there wasn’t a taxable transaction and that an independent group entity in a different EU country isn’t considered a fixed establishment solely based on a connection recognized under corporate law.
  • A fixed establishment exists only when substituting for a headquarters situated in another EU country’s territory.


Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.


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