This is a dispute between M-GbR, a German company, and the German tax authorities regarding prepaid vouchers used to purchase digital content in an online shop. The vouchers, known as ‘X cards’, were used to load user accounts for purchasing digital content from shop X. The cards were issued by a UK-based company and marketed in the EU with different country codes. M-GbR purchased these cards from suppliers in other EU member states. The disagreement arose because the tax authorities considered the cards to be multi-purpose vouchers, while M-GbR argued that the domicile or habitual residence of the end customer was not known with certainty at the time of sale.
Source KPMG
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