Painting Tanks Permanently Attached to Czech Property Requires a Czech VAT Place-of-Supply Analysis

• Painting tanks permanently attached to land in the Czech Republic may constitute a service connected with immovable property. If so, the VAT place of supply is the Czech Republic rather than Poland, even though the supplier is a Polish company and the customer is a Czech business.
• The Polish supplier must determine how Czech VAT is accounted for, including whether the Czech customer applies a domestic reverse charge or the supplier must register locally. The invoice date and payment date do not by themselves move the place of supply back to Poland.
• Contracts and work records should demonstrate the tanks’ physical and functional connection with the property. Businesses should review local VAT registration, invoice wording, reporting and evidence requirements before starting work, while separately determining Polish CIT revenue recognition under the applicable income-tax rules.

Source Gazeta Prawna: VAT and CIT treatment of painting tanks on property abroad

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