VAT Treatment of a Mobile App Selling Digital Tokens for Self-Service Car Washes

Summary

On 7 July 2026, the Croatian Tax Administration issued Opinion No. 410-01/26-01/924 on the VAT treatment of a mobile application used to buy digital tokens for self-service car washes.

Where the app provider acts in the name and on behalf of car-wash operators, customer funds collected for the operators can be treated as pass-through amounts, with the provider’s taxable revenue generally limited to its commission or platform fee.

The car-wash operator normally accounts for VAT on the washing service, while the app provider accounts for VAT on its platform/intermediary services — subject to separate analysis of any VAT exemption for payment-related services and whether the digital tokens are single-purpose or multi-purpose vouchers.

Extended article

In Opinion No. 410-01/26-01/924, issued on 7 July 2026, the Croatian Tax Administration examined the VAT treatment of a mobile application through which customers purchase digital tokens to pay for self-service car washes. The question is a familiar one in the platform economy: when a technology provider sits between the end customer and the underlying service supplier, is the provider selling the underlying service, or merely intermediating and collecting payment on the supplier’s behalf?

The Tax Administration’s answer turns on the contractual arrangements and economic reality. Where the app provider acts in the name and on behalf of the car-wash operators, the funds it collects from customers for those operators can be treated as pass-through amounts. In that case, the provider’s own taxable revenue is generally limited to the commission or platform fee it retains, rather than the gross amount paid by the customer. The car-wash operator would then account for VAT on the washing service supplied to the customer, while the app provider accounts for VAT on its platform or intermediary services.

The Opinion flags two further points that require separate analysis. First, the VAT treatment of any payment-related element of the provider’s activity must be tested against the VAT exemption for payment and transfer services — an exemption that is construed narrowly and does not extend to general technical or platform services. Second, the digital tokens themselves must be characterised as either single-purpose vouchers (SPVs) or multi-purpose vouchers (MPVs). If the place of supply and the VAT due are known at issuance, the tokens are likely SPVs, taxed when sold; if not, they are MPVs, generally taxed on redemption. That distinction affects both timing and who accounts for the VAT.

For operators of car-wash apps — and, more broadly, for any platform selling tokens, credits or vouchers redeemable for services — the Opinion is a useful reminder to document the agency relationship precisely, separate pass-through collections from the platform’s own fee, and classify tokens under the voucher rules before deciding when VAT is due. The analysis is fact-specific, so contractual terms and money flows should be aligned with the intended VAT treatment.

Sources: Porezna uprava – Opinion No. 410-01/26-01/924 · KPMG – Inside Indirect Tax (Aug 2026)