How did the EU Member States implemented ”Domestic Reverse-Charge” (Art. 194 of the Directive 2006/112)?

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Article 194 (EU VAT Directive 2006/112/EC) – Domestic Reverse Charge for non-established suppliers – is optional for EU countries. Below is an EU-wide overview of each Member State’s current implementation, including whether it’s adopted, how it’s applied (scope, conditions, deviations), and any future changes. (Article 194 allows an EU country to make the customer liable for VAT on domestic sales made by a supplier with no establishment in that country, instead of the supplier charging VAT. All scenarios assume the customer is VAT-registered locally, since that is generally required for reverse-charge to apply.)

Austria

Implemented? Yes (partially). Austria applies Article 194 only to certain transactions, not all. Implemented mainly for services by foreign suppliers, and specific goods cases.

Scope & Application: If a non-established supplier (no Austrian establishment) provides services in Austria to an Austrian taxable person, the reverse-charge mechanism applies. The foreign supplier issues an invoice without Austrian VAT, and the Austrian customer self-accounts for the VAT. Exceptions: Austria excludes a few service types – notably admission to events in Austria and the use of Austrian toll roads still require the foreign supplier to register and charge Austrian VAT (these are explicitly excepted under Austrian law)1. Additionally, a foreign landlord renting out Austrian property must register (letting immovable property is excluded from reverse-charge)2 3.

For goods, Austria did not implement a blanket reverse-charge. Ordinary goods sales by a foreign company in Austria generally require the supplier to VAT-register in Austria and charge Austrian VAT. A partial exception is if goods are supplied with installation or assembly in Austria: those are treated effectively as a service; Austrian law includes “goods assembled in Austria” by a foreign supplier under reverse-charge4 5. Also, supplies of natural gas, electricity, and heating/cooling energy by foreign traders to Austrian VAT-registered buyers fall under reverse-charge6 7 (per §19 of the Austrian VAT Act).

Austria has a peculiar alternative mechanism for goods: when a foreign company sells goods in Austria and reverse-charge does not apply, a “VAT withholding” system may kick in (the Austrian customer withholds the VAT and pays it to the tax office)8. This is an Austrian national solution to avoid forcing certain foreign suppliers to register, but it’s separate from Article 194.

Future Changes: No announced country-specific changes before the upcoming EU reform. By 1 July 2028, under the EU’s VAT in the Digital Age (ViDA) package, Austria (like all states) will be required to allow reverse-charge for all B2B supplies by non-established suppliers to VAT-registered customers9 10. Austria will need to extend its reverse-charge to cover all goods by 2028, eliminating the current limits.

Belgium

Implemented? Yes (broadly). Belgium has a broad article 194 implementation covering all domestic supplies of goods or services by foreign (non-established) suppliers, but with a notable deviation on customer status.

Scope & Application: A non-established supplier (no Belgian establishment) making any taxable supply in Belgium can use domestic reverse-charge if the customer qualifies11. This covers goods located in Belgium and services with Belgium as place of supply. It is irrelevant whether the foreign supplier is Belgian VAT-registered or not – even a foreign company that has a Belgian VAT number can invoice without VAT under this rule, as long as it has no establishment in Belgium12. The key conditions are on the customer side: the Belgian customer must be either (a) a taxable person “established” in Belgium (with a Belgian business establishment) or (b) a taxable person not established in Belgium but who is VAT-registered via a fiscal representative in Belgium13. If the customer is only directly registered for VAT in Belgium (without a fiscal representative and no local establishment), Belgium does not allow Article 194 reverse-charge14. In that case, the foreign supplier is obliged to charge Belgian VAT (so Belgium historically has been stricter, requiring some foreign buyers to appoint fiscal reps to use reverse-charge).

Invoice reference: Belgian law requires that invoices for reverse-charged supplies include the wording “Autoliquidation – art. 51 §2, 5° (Belgian VAT Code)”, indicating domestic reverse-charge15. (Article 51§2(5°) of the Belgian VAT Code is the legal basis implementing Article 194.)

National deviations: In summary, Belgium’s implementation is broad in scope of transactions but narrow in eligible customer type – essentially excluding foreign customers who only have a direct Belgian VAT registration. (Belgium’s rationale is to ensure a local responsible party for VAT; this condition is unique among Member States.) Aside from Article 194 cases, note that Belgium also applies reverse-charge domestically in other specific scenarios (e.g. certain construction works, as per Royal Decree No.1, art. 20) but those are separate from Article 194 and apply generally when both parties are Belgian VAT persons16.

Future Changes: Belgium has not yet removed its special “fiscal representative” requirement. However, under the ViDA reforms effective 2028, Belgium will be obliged to accept reverse-charge for any VAT-identified customer, even those with direct registration17 18. This means Belgium will have to drop the fiscal representative condition by 1 July 2028, aligning its rule with the standard that any customer with a Belgian VAT number can be the liable party. No other major changes are known before that deadline.

Bulgaria

Implemented? Yes (partially). Bulgaria allows Article 194 reverse-charge in certain cases – primarily for services and specific goods – but a foreign supplier selling ordinary goods in Bulgaria generally still must register.

Scope & Application: Under Article 82(2) of the Bulgarian VAT Law, when a supplier established outside Bulgaria makes a supply in Bulgaria to a VAT-registered recipient in Bulgaria, the VAT can be shifted to the recipient19 20. In practice:

Services: Any service supplied in Bulgaria by a non-established company to a Bulgarian taxable person falls under reverse-charge (except if the service is VAT-exempt)21. This includes scenarios like a foreign firm providing services related to Bulgarian real estate or performing work in Bulgaria – the Bulgarian customer must account for the VAT. (By default cross-border B2B services fall under Article 196, but Article 194 covers those few services that are deemed supplied in BG).

Goods: Bulgaria implemented the reverse-charge for certain goods situations: notably, if a foreign supplier supplies goods that are installed or assembled in Bulgaria for a Bulgarian VAT-registered buyer, the buyer must self-charge the VAT22. Similarly, supplies of natural gas, electricity, heating, or cooling energy by a foreign supplier to a Bulgarian taxable person use reverse-charge23. However, regular goods deliveries (without installation) made domestically by a foreign seller are not automatically reverse-charged. In such cases, the foreign supplier is usually required to register for Bulgarian VAT and charge VAT on the invoice (unless another simplification like call-off stock applies). Bulgaria does not have a general “any goods by foreigner” rule under Article 194.

Customer condition: The Bulgarian customer must be VAT-registered in Bulgaria for these rules to apply (if not, the mechanism cannot operate, and the foreign supplier would need to handle the VAT)24.

Other domestic reverse-charge: Separately, Bulgaria has a domestic reverse-charge (under Annex 2 of the VAT law) for industries prone to fraud (e.g. scrap materials, certain crops, emission permits)25, but that applies to all suppliers (even Bulgarian ones) and is under Article 199a of the Directive, not Article 194.

Future Changes: No specific national changes announced. Bulgaria will need to extend reverse-charge to all B2B supplies by foreign sellers by 2028 as per the EU’s mandatory rule. This will mainly impact foreign suppliers of ordinary goods, who in the future will no longer need Bulgarian VAT registration for B2B sales.

Croatia

Implemented? Yes (partially). Croatia has Article 194 provisions, but tied to the supplier’s VAT registration status. In essence, reverse-charge is used if the foreign supplier hasn’t VAT-registered in Croatia.

Scope & Application: If a supplier not established in Croatia makes a taxable supply in Croatia and is not registered for Croatian VAT, then the Croatian customer (if VAT-registered) becomes liable for the VAT. This covers both goods and services. For example, a non-established company selling goods located in Croatia to a Croatian business, without having a Croatian VAT number, can issue the invoice without VAT – the buyer will reverse-charge it26. Likewise, services carried out in Croatia by a foreign provider (place of supply Croatia) can be reverse-charged to the local client under this rule. However, if the foreign business does register for VAT in Croatia (or if it has a fixed establishment in Croatia), then this simplification isn’t used – the supplier would charge Croatian VAT normally. Croatia’s rule thus depends on the foreign supplier’s registration status: no local VAT ID => use reverse-charge; with local VAT ID => charge VAT.

Customer condition: The Croatian customer must be a VAT-registered taxable person in Croatia for the reverse-charge to apply. Croatian law effectively mirrors the Directive’s intention: the burden shifts only if the domestic customer is capable of accounting for the tax.

Note: In practice, many foreign suppliers choose not to register in Croatia if their only transactions are B2B, relying on this reverse-charge mechanism. There is no special threshold or sector limitation explicitly for Article 194 in Croatia – it’s a general condition. (Croatia also uses domestic reverse-charge for certain Croatian-specific cases like construction services, scrap, etc., but those apply regardless of supplier establishment and are pursuant to other articles.)

Future Changes: No immediate changes until the EU-wide update. Come July 2028, the EU law will guarantee that foreign suppliers can opt for reverse-charge for all B2B sales to Croatian VAT payers, even if the foreign supplier holds a Croatian VAT registration. Croatia will adjust any remaining technical conditions to meet the “shall allow” requirement then.

Cyprus

Implemented? Yes (partially). Cyprus applies Article 194 primarily to services performed in Cyprus by foreign suppliers and to certain installed goods. It does not broadly cover all goods.

Scope & Application:

Services: When a non-established supplier provides a service that is considered supplied in Cyprus (under VAT place-of-supply rules) to a VAT-registered person in Cyprus, the Cypriot reverse-charge applies. The local business customer must account for the VAT. In practice this affects services like: work on immovable property located in Cyprus by a foreign supplier, catering services in Cyprus by a foreign caterer, or any other exception to the general B2B rule where Cyprus ends up as the place of supply. (Most standard B2B services are already taxed in the country of the customer under Article 196 – which Cyprus implements as well – so Article 194 complements that by covering cases where the service is taxed in Cyprus even though the supplier is foreign.)

Goods: Cyprus permits reverse-charge for a supply of goods with installation or assembly in Cyprus by a non-established supplier. If, for example, a foreign company sells machinery and sends staff to install it in Cyprus for a taxable customer, the customer can self-charge the VAT (the foreign supplier need not register in Cyprus for that transaction).

Limitations: A foreign company making a plain sale of goods in Cyprus (without installation) is not covered by a reverse-charge override – such a supplier must register for Cypriot VAT to charge VAT on the sale. Cyprus did not adopt a general foreign-seller rule for goods.

Conditions: The domestic customer must be VAT-registered in Cyprus (under Article 10 of Cyprus VAT Law) for reverse-charge to work. If a foreign supplier sells to a Cypriot business that is not VAT-registered (e.g. below registration threshold or an exempt entity), then the foreign supplier still has to register and charge VAT; reverse-charge cannot be used in that case.

Future Changes: Cyprus has indicated no planned changes prior to the EU’s mandate. By 2028, under EU law, Cyprus will need to allow reverse-charge for all B2B supplies by non-established suppliers to VAT-identified customers, including cases of goods without installation. This will be a minor expansion of Cyprus’s current rules.

Czech Republic

Implemented? Yes (partially). The Czech Republic’s legislation implements Article 194 mostly for goods supplied by foreign sellers, and by wording doesn’t list all services – though in practice foreign-supplied services to businesses are also handled via reverse-charge through general rules.

Scope & Application: According to the Czech VAT Act (in section 108), domestic supplies of goods in Czechia by a supplier not established in Czechia are subject to reverse-charge if the supplier is also not registered as a Czech VAT payer and the customer is a Czech VAT payer27. Essentially, if a foreign company without a Czech VAT number sells goods located in the Czech Republic to a Czech VAT-registered business, the foreign supplier does not charge Czech VAT – the Czech buyer reports both output and input VAT. This covers typical scenarios like a foreign business selling inventory within CZ to a local company without having any local establishment. If the foreign supplier is registered as a VAT payer in CZ, then Czech reverse-charge does not apply (the supplier must charge VAT normally).

Services: The Czech law’s text on Article 194 specifically mentions goods. However, for services provided by a non-established supplier with a place of supply in Czechia (e.g., services related to Czech real estate, catering in Czechia by a foreign firm, etc.), Czech practice also applies reverse-charge. In fact, Czech authorities treat the non-established supplier similar to goods: if they have no CZ establishment and no CZ VAT registration, the Czech customer should self-account for VAT. Many such services are anyway covered by Article 196 (general B2B rule) if the customer is a business. For those few exceptions where Article 194 is needed (like short-term hire of a car in Czechia by a foreign lessor to a Czech business), the reverse-charge would be applied under the non-established supplier clause in Czech law. So effectively, foreign-supplied services to Czech VAT payers are also reverse-charged, even if not explicitly highlighted in the law’s summary.

Conditions: The Czech customer must be a VAT-registered person (“plátce DPH”) in Czech Republic. If a foreigner sells to a non-VAT-registered Czech entity, then the foreigner must register in CZ to remit VAT (since reverse-charge can’t operate).

Note: Czech Republic has also implemented various domestic reverse-charge mechanisms for specific high-fraud sectors (like construction work, certain electronics, etc.) under Czech VAT Act §92a onwards, but those apply regardless of whether the supplier is foreign or local. They are separate from Article 194 and remain optional measures used within Czechia.

Future Changes: No major changes announced. Under the EU’s 2028 mandate, any remaining restrictions (e.g. the requirement that the supplier not be VAT-registered in CZ) will be lifted – foreign companies will be allowed to use reverse-charge for B2B sales even if they have obtained a Czech VAT number. Czech law will be adjusted to comply with the “shall allow” phrasing but this is largely an affirmation of current practice.

Denmark

Implemented? Yes (limited). Denmark has a very limited implementation of Article 194 – it chose to apply reverse-charge only to a few defined supply types by foreign entities, rather than a general rule. If a foreign supplier sells most normal goods in Denmark, they still must register; Denmark’s Article 194 adoption is narrow.

Scope & Application: Key scenarios where Denmark uses domestic reverse-charge for non-established suppliers:

Goods with installation: If a foreign business supplies goods that are assembled or installed in Denmark for a customer, Danish law makes the customer liable for the VAT. For example, a German company installing equipment in Denmark for a Danish factory will not charge Danish VAT; the Danish customer will reverse-charge it. (The foreign supplier must have no fixed establishment in DK).

Energy supplies: Supplies of natural gas or electricity (through the network) by a foreign trader to a Danish VAT-registered buyer are done under reverse-charge. Similarly, supplies of heat or cooling via networks by foreign suppliers are included.

Other goods/services: Denmark did not implement Article 194 for general goods or all services. If a non-established company sells goods in Denmark (and those goods aren’t installed or covered by another special rule), the foreign supplier must register for Danish VAT and charge 25% VAT on the invoice. Likewise for services: most B2B services to Danish businesses from abroad fall under Article 196 (so Danish customer accounts anyway), but if the service’s place of supply is Denmark under an exception (for instance, a foreign organizer selling tickets to an event in Denmark to a Danish company), Denmark currently requires the supplier to register and charge VAT (Denmark did not extend Article 194 to event admissions, etc.).

Conditions: Where it applies, the Danish customer must have a VAT registration (be a taxable person). Notably, for installed goods, even a foreign customer VAT-registered in DK would trigger reverse-charge in Denmark – meaning if, say, a Swedish company (non-established in DK) buys installed machinery in Denmark, that Swedish company would need to have a Danish VAT number and reverse-charge the VAT.

Future Changes: No Denmark-specific changes foreseen before the EU law change. By July 2028, Denmark will be required to widen its use of reverse-charge to all B2B supplies by non-established suppliers (assuming the customer has a VAT number). This will be a significant expansion for Denmark, effectively removing the current limitations. Danish VAT law will be amended accordingly to comply with the mandatory approach.

Estonia

Implemented? Yes (partially). Estonia allows reverse-charge for non-established suppliers in a general way, but effectively it’s tied to whether the foreign supplier is VAT-registered locally. The rule is similar to that of several other countries like Finland.

Scope & Application: If a supplier from abroad (no Estonian establishment) makes a taxable supply in Estonia and is not registered for VAT in Estonia, the Estonian VAT law makes the Estonian business customer liable for the VAT. In other words, as long as the foreign supplier has not taken out an Estonian VAT number, any B2B sales it makes in Estonia can be done under reverse-charge (with the Estonian buyer self-assessing the VAT). This covers goods and services alike. For example, a non-resident company selling goods located in Estonia to an Estonian VAT-registered buyer does not charge Estonian VAT if it isn’t registered; the buyer reports the VAT. The same if a foreign company provides a service in Estonia (that isn’t already taxed under general EU B2B rules) – the local buyer pays the VAT to the state. If the foreign company voluntarily or obligatorily registers for VAT in Estonia, then it must charge VAT as normal (Article 194 is used as a simplification only when the supplier hasn’t registered).

Customer condition: The Estonian customer must be a VAT-registered person in Estonia. If a foreign supplier sells to an Estonian entity that doesn’t have a VAT number, the foreign supplier can’t use reverse-charge and would need to register in Estonia to charge VAT.

Note: Estonia’s implementation is broad in terms of types of transactions (no specific exclusions are given in law apart from general exceptions like VAT-exempt supplies). Essentially, it provides a “non-established + not registered = reverse-charge” rule. There are no special thresholds or industry limitations under Article 194 in Estonia. (Estonia does separately have domestic reverse-charge for some metals, waste, etc., irrespective of supplier origin, as anti-fraud measures, but those are separate provisions.)

Future Changes: No specific changes announced prior to the EU mandate. Estonia’s practice will continue as is until 2028, when the EU Directive will require that even if a foreign supplier is registered in Estonia, the reverse-charge may be used at the supplier’s discretion. Estonia will adjust its legislation to ensure it “shall allow” reverse-charge whenever the customer is VAT identified locally.

Finland

Implemented? Yes (partially). Finland’s rules mirror the Estonian/Polish model: the reverse-charge is available when the foreign supplier has not registered for Finnish VAT. It covers both goods and services from non-established suppliers, with some exceptions unlikely.

Scope & Application: In Finland, if a non-established supplier (no business establishment in Finland) makes a supply of goods or services in Finland without having a Finnish VAT registration, then the Finnish customer is liable for the VAT (reverse-charge). This means a foreign company selling goods located in Finland to a Finnish VAT-registered business would normally not charge Finnish VAT; the Finnish buyer declares the VAT. Likewise, a foreign firm providing taxable services in Finland to a Finnish business would rely on the Finnish customer to account for the VAT. However, if the foreign company opts to register for VAT in Finland or is required to (e.g., for making B2C supplies), then it would charge VAT itself and the reverse-charge would not be used.

Customer condition: The Finnish customer must be VAT-registered (a taxable person) in Finland for reverse-charge to apply. If a sale is made to a non-registered entity, the foreign supplier can’t shift the VAT and must take care of it (which usually means obtaining a VAT number in Finland and charging VAT).

Scope notes: Finland did not enumerate a list of included/excluded transactions in the law text – it generally allows the mechanism for any taxable supply by a foreign supplier. (Certain specific supplies like investment gold or second-hand goods could have their own regimes, but that’s separate). So practically all B2B supplies by foreign suppliers to Finnish VAT payers qualify, except where EU law mandates a different treatment.

Legislation: The Finnish VAT Act (Arvonlisäverolaki) contains this rule – often cited in Section 9 of the act. It aligns with Article 194’s permission.

Future Changes: Finland’s approach is already straightforward. No interim changes expected. Under the EU’s 2028 changes, Finland will formally broaden the rule so that even a foreign supplier with a Finnish VAT number can still choose to have the Finnish buyer account for VAT. In practice, Finland already seldom forces foreign B2B suppliers to register, so it’s largely in line.

France

Implemented? Yes (fully). France has a very broad and straightforward implementation of Article 194. Essentially all domestic B2B supplies by non-established suppliers are under reverse-charge, with minimal conditions.

Scope & Application: If a supplier is not established in France, French VAT law (General Tax Code, Article 283-2) makes the customer liable for the VAT on any taxable supply of goods or services in France28. Importantly, France does not require the foreign supplier to be unregistered – even if the foreign company holds a French VAT number, it can issue a VAT-free invoice as long as it has no establishment in France. Likewise, it doesn’t matter whether the customer is established in France or not; what matters is the customer has a French VAT identification. So for example:

A German firm selling goods located in France to a French VAT-registered company: the German firm does not charge VAT, the French buyer self-accounts.

A US company performing a service in France (say a repair on French equipment) for a French business: no French VAT on the invoice, French client reverse-charges.

If a French company buys goods from a foreign supplier at a French trade show, with the foreign supplier having no French establishment – the French buyer pays the VAT via reverse charge. In all such cases, the mechanism is allowed.

Conditions: The only real condition is that the customer is “identified for VAT” in France (i.e., has a French VAT number)29. If the customer is a French private consumer or a non-VAT-registered entity, then Article 194 cannot apply and the foreign supplier would need to register to charge VAT. Also, if the foreign supplier does have a fixed establishment in France that intervenes in the supply, then the supplier is considered established and must charge VAT (i.e., the reverse-charge is only for suppliers with no French establishment involved in the transaction).

No exclusions: France did not carve out any particular sectors or transaction types from this rule. Practically, all goods and services (that aren’t VAT-exempt) supplied by foreign companies to French VAT-registered customers fall under it. This comprehensive approach has made it easier for foreign businesses to operate in France without registration for B2B sales. French tax authorities instruct such suppliers to include the reference “Autoliquidation – article 283, CGI” or a mention of Directive 2006/112/EC Article 194 on the invoice as a note.

Future Changes: France already meets the upcoming requirements, as its rule is very liberal (the customer just needs a VAT number). There are no major changes needed or planned before 2028. Under ViDA, Article 194 will become mandatory EU-wide, but France’s law is already in line with the “shall allow” principle. The only difference is that what is now an optional measure will become a binding rule – but French implementation likely remains the same.

Germany

Implemented? Yes (partially). Germany applies Article 194 extensively for services and some goods, but notably did not extend it to most goods deliveries. Consequently, foreign suppliers of standard goods in Germany still must VAT-register. German law (UStG §13b) defines the cases where reverse-charge applies for non-established suppliers.

Scope & Application:

Services: Germany uses reverse-charge for nearly all services supplied by a non-established business to a German business customer. If a foreign company (with no German establishment) performs a service and the place of supply is Germany, the German customer is liable for VAT (§13b(5) German VAT Act)30 31. This covers a broad range of services – e.g. consulting in Germany, repairs of movable items in Germany, property services on German land, etc. Exceptions: A few specific service types are excluded by German law, meaning the foreign supplier must register to bill VAT on them. These include passenger transport services within Germany, catering services provided on board trains/planes that travel in Germany, and short-term hiring of vehicles in Germany, as well as event admission services (cultural, artistic, sporting admissions in Germany by foreign organizers are taxed via the organizer)32. Aside from these niche cases, any service a foreign firm provides to a German VAT-registered entity is usually under reverse-charge. (Notably, Germany even considers reverse-charge applicable if the customer is not yet VAT-registered but is a business – effectively the customer must then retroactively remit VAT – but in practice most customers are registered, so this nuance rarely surfaces)33.

Goods: Germany’s Article 194 implementation for goods is limited to supplies involving installation or assembly. If a foreign supplier (with no German establishment) supplies goods in Germany and also installs or assembles them on site for a business customer, then the German customer must pay the VAT under reverse-charge (German VAT Act §13b(2) Nr.1). This relieves foreign companies of registering when they send staff to install equipment, etc. However, for ordinary goods sales (without installation), Germany did not implement reverse-charge. A foreign company selling goods located in Germany to German customers must register for German VAT and charge German VAT on those sales (unless another simplification like call-off stock or an intra-Community supply applies). For example, a French company warehousing goods in Germany and selling to German retailers must obtain a German VAT number and charge VAT – Germany did not use Article 194 to simplify that.

Summary of deviations: Germany is relatively generous on services, strict on goods. It also uniquely excludes some services (like event admissions) where many other countries would use Article 194 – meaning foreign event organizers must VAT-register in Germany. Additionally, Germany has a variety of domestic reverse-charge rules (also in §13b) that apply regardless of supplier origin – e.g. construction work, certain supply of mobile phones and electronics above thresholds, trading gas/electricity with resellers, emissions permits trading, etc.34 – but those are separate from the non-established supplier clause.

Conditions: The German customer must be a taxable person (business) for reverse-charge. If a foreigner somehow supplied a service or installed goods to a German private individual, the foreign supplier would have to handle German VAT (reverse-charge never puts liability on private consumers). In most B2B cases, the German customer’s VAT ID is used as proof.

Future Changes: Germany will need to adjust its approach by 2028 to comply with the ViDA mandate. The future EU rule will force all Member States to allow reverse-charge for any B2B transaction by a foreign supplier. For Germany, the biggest change will be in the area of goods: foreign sellers of goods in Germany (who currently must register) will be able to opt for reverse-charge. Germany will have to remove its restriction for goods without installation. Additionally, the few service exceptions may become irrelevant if EU law doesn’t allow them (though some exceptions like event admissions might be covered by Article 194’s “without prejudice to Article 195”, etc., so we will see if Germany retains those). In short, by 1 July 2028, Germany will enact the necessary changes so that any foreign supplier without a German establishment can have the German business customer pay the VAT (the customer just needs a VAT ID).

Greece

Implemented? No (not generally). Greece did not implement Article 194 for the typical non-established supplier scenario. Unlike most EU countries, Greece requires foreign suppliers to register and charge VAT for domestic supplies.

Current Policy: When a foreign (non-established) company makes a taxable supply of goods or services in Greece, Greek VAT must be charged by the supplier as a rule. Greece decided not to use the optional reverse-charge simplification for general cases. This means:

If, say, an Italian company sells goods located in Greece to a Greek business, the Italian company must register for VAT in Greece and apply Greek VAT on the invoice (the VAT can later be reclaimed by the Greek business in its return, but it’s charged and collected by the supplier).

If a US company performs a service in Greece (with Greece as the place of supply, e.g. a catering service at a Greek event), that US company likewise must register and charge Greek VAT to the customer. In both cases, reverse-charge cannot be used to shift the obligation to the Greek customer (unless a specific exception applies – see below).

Cross-border services: It should be noted that many B2B services provided to Greek businesses are actually taxed under Article 196 (general B2B rule) which is implemented in Greece. For instance, consulting services by a foreigner to a Greek company are taxed in Greece but via the Greek customer (no Greek VAT on invoice). That is not due to Article 194, but the general rule for cross-border services. Article 194 would have been relevant for cases like: services physically performed in Greece (where place of supply = Greece) by a foreigner – e.g., construction, catering, short-term hiring, etc. In those cases, since Greece has not implemented 194, the foreign supplier must handle Greek VAT.

Limited reverse-charge cases: Greece does apply domestic reverse-charge in specific sectors (allowed by other articles of the Directive). For example, Greece uses reverse-charge for certain categories of scrap and waste materials, precious metals, and some construction services (Article 39a of Greek VAT Code). These apply regardless of supplier establishment and are intended to combat VAT fraud. But these are not implementations of Article 194’s non-established supplier rule – they’re separate national measures. In summary, Greece currently has no general reverse-charge for foreign suppliers – if you’re making a supply in Greece, you almost always need a Greek VAT number.

Future Changes: Greece will be compelled to change its stance due to EU law. The European Commission’s ViDA reforms mean that by 1 July 2028 all Member States must “shall allow” domestic reverse-charge for non-established suppliers35. Greece will therefore implement Article 194 at that time. Greek VAT legislation will be amended so that if a supplier has no establishment in Greece and is selling to a VAT-registered person in Greece, the Greek customer will be liable for the VAT. This will be a significant shift for Greece. It’s expected as a part of Greece’s adaptation to the Single VAT Registration initiative EU-wide. No other known changes before that date; Greece is likely to maintain the status quo until required to change.

Hungary

Implemented? Yes (in a limited way). Hungary’s use of Article 194 is not blanket; it’s intertwined with its domestic reverse-charge rules. Hungary applies reverse-charge for some supplies by foreign entities, mostly specific services or goods in defined sectors, but has not generally exempted all foreign suppliers from registration.

Scope & Application: Hungarian VAT law (specifically Section 140-142 of the VAT Act) lists cases of reverse-charge. Many of these cases are sector-specific (allowed under Articles 199-199a of the Directive). For non-established suppliers (Article 194 context), the relevant cases include:

Services: If a foreign (non-established) taxable person provides a service in Hungary to a Hungarian VAT-registered person, typically the VAT is shifted to the customer. For instance, a foreign company without a Hungarian establishment delivering construction services on Hungarian real estate to a Hungarian business will not charge VAT; the Hungarian customer self-assesses the VAT (this is explicitly listed in the Hungarian rules). Likewise, other services where Hungary is the place of supply (like catering in Hungary by a foreigner, etc.) to a business, the Hungarian customer is liable for VAT. (Note: cross-border B2B services falling under the general rule are anyway covered by Article 196.)

Goods: Hungary did not adopt a general reverse-charge for all goods supplied by foreign suppliers. If a foreign company sells ordinary goods in Hungary to a Hungarian buyer, the default requirement is that the foreign company register for VAT in Hungary and charge Hungarian VAT. However, Hungary has some particular cases where even goods can be reverse-charged: for example, investment gold supplies are reverse-charged, and from 2021 certain supplies of goods like real property under enforcement, etc., are reverse-charged – but these apply regardless of supplier origin. The key Article 194-related scenario is goods installed or assembled in Hungary by a foreign supplier (similar to other countries). Hungarian practice is to consider those as construction services, which are reverse-charged to the customer. If a foreign firm sells equipment and installs it in Hungary for a business buyer, the buyer owes the VAT (Hungarian VAT Act §142 includes installation as a construction service category).

Other specific cases: Hungary’s VAT Act §142 covers many specific domestic reverse-charge cases: e.g. sale of waste and scrap materials, certain agricultural products, sale of emission quotas, and grains/seeds, even supplies of staff in construction – these apply whether the supplier is local or foreign. So foreign suppliers might avoid registration if their supplies fall into these categories since the Hungarian customer must reverse-charge. But if a foreign supplier’s activity doesn’t fall into one of the listed categories (and it’s a goods supply), Hungary does not provide a reverse-charge. This is why Hungary is known to require foreign companies to register for many types of goods sales.

Customer condition: As usual, the Hungarian customer must be VAT-registered in Hungary for reverse-charge to apply. If not, the foreigner has no choice but to register and charge VAT.

Summary: Hungary partially implemented Article 194 – mainly ensuring foreign-provided services and certain installed goods are covered. But it withheld full implementation for general goods to maintain tax control. The Hungarian approach prioritizes using targeted reverse-charge for high-risk supplies, rather than a blanket rule freeing all foreign B2B suppliers from registration.

Future Changes: Hungary has not announced plans to broaden its reverse-charge regime ahead of the EU requirement. With the ViDA changes, by 2028 Hungary must allow reverse-charge for all B2B supplies by non-resident suppliers (no matter the category). This will represent a considerable change: foreign businesses selling standard goods to Hungarian companies will then no longer need to register in many cases. Hungary will adapt its VAT Act accordingly, likely by adding a general clause for non-established suppliers (or modifying the existing “foreign trader” provisions).

Ireland

Implemented? Yes (partially). Ireland uses Article 194 for certain cases – primarily services and goods involving installation – but not for all situations. Foreign suppliers still must register in some scenarios (notably for general goods sales).

Scope & Application:

Services: Ireland’s VAT law (VAT Consolidation Act 2010, s.12 and s. reverse-charge provisions) provides that when a supplier not established in Ireland supplies a taxable service in Ireland to an Irish VAT-registered person, the reverse charge applies. Practically, this means if the place of supply of a service is Ireland (for example, certain cultural services, real estate services on Irish land, passenger transport in Ireland by a foreigner, etc.), and the supplier is not established in Ireland, the Irish customer must account for the VAT. (If it were a normal cross-border B2B service, it would already fall under the general rule with the same effect.) Irish Revenue guidance explicitly states that services such as land-related services, hire of movable goods in Ireland, or catering in Ireland provided by a foreign trader to a VAT-registered Irish customer are subject to reverse-charge (the customer must “self-account”).

Goods with installation: If a foreign supplier sells goods in Ireland that involve installation or assembly and the supply is to an Irish VAT-registered customer, Ireland applies reverse-charge. The Irish customer will pay the VAT in their return (Irish VAT Act Section 17(1) covers this scenario). So, for example, a UK company installing machinery in an Irish factory would not charge Irish VAT; the factory (if VAT-registered) would declare the VAT.

Construction services: Ireland has a special reverse-charge in the domestic construction sector that also covers foreign suppliers. If a non-established subcontractor provides construction services to a VAT-registered principal contractor in Ireland, the principal contractor must account for the VAT (this is a long-standing measure to ease compliance in construction). So many foreign building contractors working for Irish developers do not register; the Irish customer handles the VAT under this rule.

Energy products: Supplies of gas and electricity by foreign suppliers to taxable dealers in Ireland also fall under a reverse-charge (as per Irish VAT Act Section 56 and EU rules), meaning an Irish reseller buying electricity from abroad accounts for the VAT.

General goods: Ireland did not implement a general reverse-charge for all goods. A foreign company selling standard goods located in Ireland to Irish businesses is generally required to register for VAT in Ireland and charge Irish VAT on those sales. For instance, a French company storing goods in Ireland and selling to Irish retailers needs an Irish VAT number – reverse charge is not available to bypass that (unless those goods qualify as installed or are under a call-off stock simplification etc.).

Customer condition: The Irish customer must be VAT-registered (hold an Irish VAT number) for reverse-charge to apply. Unregistered businesses or consumers cannot be made liable – the foreign supplier would have to register in such cases.

Reference: The Irish tax authority’s documentation (Revenue VAT Guide) confirms these points and directs that invoices by foreign suppliers for such reverse-charge scenarios should include a phrase like “VAT to be accounted for by the recipient”.

Future Changes: No specific national changes are slated prior to the EU’s harmonization. By 2028, Ireland will adjust its law in line with EU requirements so that any foreign supplier selling to a VAT-registered Irish customer can use reverse-charge (removing the current necessity for foreign B2B sellers of goods to register in Ireland). This will primarily affect scenarios of foreign companies selling goods warehoused in Ireland to Irish buyers. Ireland’s existing reverse-charge setups already cover most other cases, so the adaptation should be straightforward.

Italy

Implemented? Yes (fully). Italy has implemented Article 194 in an extensive manner, often referred to as “reverse charge for non-residents” under Article 17(2) of the Italian VAT law (DPR 633/1972). In general, all supplies of goods or services in Italy by a non-established supplier to a VAT-registered customer are subject to reverse-charge, with few restrictions.

Scope & Application: If a supplier is not established in Italy, Italian law designates the Italian customer as the VAT debtor (if the customer is a taxable person). This applies to goods delivered within Italy and services carried out in Italy. For example:

A Polish company selling a batch of goods located in Italy to an Italian company will not charge Italian VAT; the Italian purchaser will report VAT on that purchase (and deduct it if entitled).

A US firm providing consulting or even physically performed services in Italy to an Italian business will likewise not charge VAT; the Italian client will self-assess the VAT. Italy’s rule covers both scenarios. In practice, foreign companies making B2B sales into Italy very rarely need an Italian VAT number because the clients handle the VAT.

Conditions: The Italian customer must be “a taxable person established in Italy” (or a VAT-registered entity with an Italian VAT number and technically an establishment). Italy’s phrasing historically required that the customer have an establishment or fixed address in Italy. If a foreign supplier sells to another foreign company that is merely VAT-registered in Italy (with no permanent establishment), Italy did not allow reverse-charge – that supply would fall outside Article 194’s use. (This situation is not very common, but it’s a nuance: e.g., if a French company (no Italian PE) sold goods in Italy to a German company that is VAT-registered in Italy but not established there, under past Italian rules the French supplier might still need to charge Italian VAT because the German buyer isn’t “established” in Italy. In such cases often the foreign buyer itself has a VAT rep, which might satisfy being “established” through representation. It’s a technical point.) In summary, the typical case is an Italian-based company as buyer.

Few exceptions: Italy’s implementation does not list particular goods or services exceptions – it’s broadly applicable. Virtually the only cause a foreign supplier would have to register in Italy is if selling to Italian private consumers or non-VAT-registered entities, because Article 194 only shifts liability when the buyer is a taxable person. Another case is if the foreign supplier has an Italian fixed establishment that intervenes in the supply, then the supply is considered made by the Italian establishment and the reverse-charge doesn’t apply (the local establishment would charge VAT in that case).

Invoice requirements: The Italian customer receiving a reverse-charged invoice from a foreign supplier is required to issue a self-invoice or integrate the invoice and report it (the mechanism known as “inversione contabile”). The supplier often notes on the invoice “Inversione contabile – art. 17(2) DPR 633/72” indicating the reverse-charge.

Future Changes: Italy is already largely aligned with the upcoming mandatory approach. The only tweak likely needed by 2028 is to ensure the rule covers cases where the customer is merely VAT-identified in Italy (not physically established), since the new EU law will require acceptance of that scenario as well36. Italy has no separate national changes announced; the current framework will continue until the EU “shall allow” rule kicks in, cementing the practice across Europe.

Latvia

Implemented? Yes (partially). Latvia has provisions for reverse-charge when non-established businesses are involved, though the public details are less highlighted. In practice, Latvia’s rules are similar to those in Estonia/Finland: foreign suppliers often do not charge VAT if they aren’t registered locally.

Scope & Application: If a business not established in Latvia makes a taxable supply in Latvia to a Latvian VAT-registered business, the reverse-charge mechanism applies. The Latvian customer is responsible for calculating and reporting the VAT. This is codified in Latvia’s VAT law (often referenced in sections 84, 85). For instance:

A non-resident company selling goods located in Latvia to a Latvian company, without a local VAT registration, will have the Latvian buyer self-account for the VAT.

A foreign company providing services in Latvia (where under the VAT rules the place of supply is Latvia) to a Latvian taxable person will similarly not charge VAT, and the Latvian recipient will declare the VAT. Latvia explicitly notes that if a non-established supplier provides services to a Latvian VAT payer, tax “occurs in Latvia at the recipient’s place of establishment” and the recipient must report it37. This implies the core of Article 194 is active.

Practical use: Many foreign suppliers avoid Latvian VAT registration for B2B sales because of this rule. However, if a foreign company does decide to register in Latvia (or has a fixed establishment there), then it would charge VAT normally on local sales.

Customer condition: The mechanism only works if the Latvian customer is VAT-registered. If a foreigner sells to an entity not in the VAT register, the foreigner must register and handle VAT.

Note: Latvia also employs reverse-charge for some purely domestic transactions (like certain timber or metal supplies, etc., to combat fraud), but here we focus on the non-established supplier scenario. Latvia’s law did not specify unusual conditions like requiring a fiscal representative or similar – it generally aligns with the baseline directive text. There’s no special threshold for applying this (aside from normal VAT registration thresholds for the buyer, which is separate).

Future Changes: There’s no indication Latvia will change its approach before the EU-wide rule. By 2028, the EU law will ensure any remaining ambiguity is removed – foreign suppliers selling to any VAT-identified Latvian business can use reverse-charge. Latvia may need to clarify the rule to explicitly include instances where the customer might not be “established” but is VAT-registered (if not already clear). Overall, Latvia’s practice should smoothly transition into the mandatory system.

Lithuania

Implemented? Yes (partially). Lithuania has implemented Article 194, but with a condition regarding the customer’s establishment. It is generally used for both goods and services by foreign suppliers when selling to Lithuanian businesses.

Scope & Application: Lithuanian VAT law (specifically Article 95(2) of the VAT Law) provides that if a supplier is not established in Lithuania and makes a taxable supply there, the VAT-registered customer in Lithuania becomes liable for the VAT (self-assessment), provided the customer is established in Lithuania. This covers:

Goods: A non-established, non-registered supplier selling goods locally in Lithuania to a Lithuanian VAT payer can do so without charging VAT; the Lithuanian buyer declares the VAT. If the foreign supplier has no Lithuanian establishment and hasn’t registered, this applies. If the foreign supplier does register for VAT in LT, then it charges VAT as normal (similar to PL, FI, etc.).

Services: Foreign-supplied services that are taxed in Lithuania (such as services related to Lithuanian property, or other exceptions to general B2B rule) are also subject to reverse-charge, with the Lithuanian recipient accounting for the tax. Most cross-border B2B services were anyway under Article 196. This ensures foreign companies don’t have to register just to perform, say, a project on Lithuanian soil for a business client – the client handles the VAT.

Customer condition: Lithuania’s nuance is the customer should be “a taxable person established in Lithuania”. If the customer is not established (e.g., a foreign company with only a VAT number in Lithuania via direct registration), the law as written might not allow reverse-charge. In practice, such scenarios are rare, and the State Tax Inspectorate likely would still find a way to apply it. But formally, the rule was aimed at Lithuanian-established buyers. All typical cases (Lithuanian company buying from foreign supplier) are covered.

No major exclusions: There are no special exclusions of transaction types under Article 194 beyond what’s stated. As long as the foreign supplier has no fixed establishment intervening in Lithuania, the reverse-charge can apply. Lithuania also has domestic reverse-charge for certain specific goods (scrap, etc.) under other provisions, like many countries.

Future Changes: Lithuania will need to fine-tune its rule by 2028 to align with the new directive wording (“customer is identified for VAT” rather than “established”). This means allowing reverse-charge even if the customer is not Lithuanian-established, as long as the customer has a LT VAT number. Otherwise, Lithuania’s practice covers the intent. No other changes are expected until the EU mandate.

Luxembourg

Implemented? Barely – Luxembourg has (until recently) essentially not implemented Article 194 for general supplies. The only case Luxembourg applied it was for certain energy supplies. Thus, foreign suppliers in most industries must register in Luxembourg if they make domestic supplies.

Scope & Application:

Up to 2022, the only Article 194-type provision in Luxembourgish law was that supplies of natural gas, electricity, heat or cooling energy through networks by a supplier not established in Luxembourg to a Luxembourg VAT-registered person were subject to reverse-charge. This narrow instance comes from the EU directive’s allowance (and many countries adopt it similarly). If, for example, a German utility sold electricity to a business in Luxembourg, the Luxembourg customer would account for the VAT (no Luxembourg VAT charged by the German utility).

No general rule for goods/services: Aside from the above energy case, Luxembourg did not offer a general reverse-charge for other goods or services supplied by non-established taxpayers. If a foreign company sold any goods located in Luxembourg to a Luxembourg client, that foreign company had to register for Luxembourg VAT and charge it. Similarly, a foreign company providing say, construction services or catering in Luxembourg to a local business must register and apply Luxembourg VAT on its invoices. Luxembourg deliberately did not take up the optional Article 194 except for the energy sector, in order to keep all suppliers in the tax net.

Recent developments: In 2022 and 2023, Luxembourg expanded domestic reverse-charge for some high-fraud items (like certain electronic devices and valuable metals) – e.g., smartphones, tablets, game consoles, and certain metals now have reverse-charge above particular invoice thresholds (these changes came via Luxembourg’s VAT law updates in 2022/2023). However, these measures apply to all suppliers in those transactions, even those established in Luxembourg, and were enacted under Article 199a of the Directive to combat fraud. They are not related to the foreign supplier rule of Article 194. So as of 2025, the general stance remains: if a foreign business sells or works in Luxembourg, they need a VAT number there (except for gas/electricity supplies).

Customer condition: In the limited cases where Luxembourg does allow reverse-charge (energy supplies), the customer must be VAT-identified in Luxembourg. For the new domestic RC on electronics, the customer also must be taxable and filing periodic returns, etc., but again that’s outside Article 194’s scope.

Future Changes: Luxembourg will be required to implement a full Article 194 mechanism by 1 July 2028 due to the EU “shall allow” change. This will mark a big shift, as Luxembourg will have to permit reverse-charge for all goods and services supplied by foreign non-established persons to taxable customers. Luxembourg authorities have been aware of this upcoming obligation under the “VAT in the Digital Age” initiative38. We can expect Luxembourg’s VAT law to be amended accordingly before that date. In short, by 2028, Luxembourg will no longer be an outlier: foreign suppliers selling in Luxembourg to businesses will generally not need to register for VAT, aligning with the rest of the EU.

Malta

Implemented? Yes (with a narrow scope). Malta has implemented Article 194 only for services; it notably did not implement it for goods. A foreign company making a domestic supply of goods in Malta must register, as Malta did not utilize the option for goods.

Scope & Application:

Services: Maltese VAT law provides that if a supplier established abroad supplies a service in Malta to a person registered under Article 10 (VAT-registered trader) in Malta, then the VAT is accounted for by the recipient (reverse-charge). This is outlined in Malta’s VAT Act, Article 20(2). In practice, virtually all B2B services by non-residents to Maltese businesses fall under this since most such services anyway come under the general B2B place-of-supply rule (Article 196). Additionally, any exceptions (like services relating to Maltese property, etc.) also invoke this reverse-charge so that the foreign service provider needn’t register. The Maltese client posts the output VAT and (if entitled) input VAT in their VAT return, resulting in a nil net effect if fully deductible.

Goods: Malta did not implement domestic reverse-charge for goods supplied by non-established entities. If a foreign company imports or already has goods in Malta and sells them locally, that company is expected to register for VAT in Malta and charge Maltese VAT on the sale. There is no provision to shift the VAT responsibility to the buyer in such cases (unlike many other EU countries). This was a conscious decision, likely for better control of tax collection. Even the call-off stock simplification (for goods warehoused for a single customer) was only adopted by Malta from 2020; prior to that, foreign companies had to register for any local stocks. So Malta has been conservative on foreign supplier situations for goods.

Customer condition: Only a VAT-registered customer (under the standard regime) in Malta can handle reverse-charge. Businesses that are VAT-exempt without credit or below threshold are not covered, nor of course consumers. Thus, foreign suppliers can only avoid Maltese VAT registration if selling to a duly VAT-registered company in Malta.

Note: Maltese tax authorities emphasize that reverse-charge for services is a simplification measure that spares the foreign supplier from Maltese obligations and streamlines input credit for the customer. Invoices from foreign suppliers should indicate that Maltese VAT is to be accounted for by the recipient.

Future Changes: Malta will have to broaden its implementation by 2028 due to the EU’s changes. Specifically, Malta will need to allow reverse-charge for goods supplied by non-established suppliers to Maltese VAT payers as well. This will be a major change in Maltese practice, effectively ending the requirement for foreign companies to register for purely B2B goods transactions in Malta. No interim changes are known; Malta will likely keep its current approach until the EU law compels the expansion.

Netherlands

Implemented? Yes (fully). The Netherlands has a very broad and simple implementation: it applies domestic reverse-charge to all supplies by non-established suppliers to Dutch businesses. The Dutch system is one of the most user-friendly for foreign traders.

Scope & Application: If a supplier is not established in the Netherlands and makes a taxable supply of goods or services in the Netherlands to a business customer, Dutch law (Turnover Tax Act 1968, Art. 12(3)) states that the customer is liable for the VAT. This covers essentially every scenario of B2B trade:

A foreign company selling goods within the Netherlands to a Dutch company – no VAT on invoice, Dutch buyer does reverse-charge (reports it in their return).

A foreign company performing any service in the Netherlands for a Dutch business – no VAT charged, Dutch client accounts for VAT. It is irrelevant whether the foreign supplier is EU or non-EU, or whether it is VAT-registered in NL or not. The key criterion is the absence of a Dutch establishment. If the foreign supplier happens to have a Dutch VAT number (maybe for other reasons), it can still zero-rate the invoice under Article 194 as long as it has no Dutch fixed establishment involved in that supply.

Conditions: The Dutch customer must be a VAT-registered entrepreneur in the Netherlands (or a legal entity required to be identified for VAT). In practice, providing the customer’s BTW (VAT) number on the invoice is enough evidence. If the customer is a private individual or not a VAT entrepreneur, then the reverse-charge cannot be used and the foreign supplier would need to register to charge VAT. Additionally, if the foreign supplier does have a Dutch fixed establishment that is involved in the supply, then that supply is considered made by the Dutch establishment and normal VAT applies (the rule only applies when the supplier truly has no establishment in NL).

No special exceptions: The Netherlands doesn’t carve out any normal transactions. Even, for instance, event admissions or short-term land leases by foreign suppliers to businesses in NL are covered. The Dutch tax authority’s guidance for non-residents plainly says: “You are not usually involved with Dutch VAT; the VAT is reverse-charged to the client”, which encapsulates the broad approach.

Note: The Netherlands historically also had a “Article 196” rule for foreign EU suppliers providing services to Dutch customers (like all EU countries). The Article 194 rule extended the reverse-charge to goods and any services not caught by Article 196. This has significantly reduced the need for foreign businesses to VAT-register in the Netherlands except for B2C activities.

Future Changes: The Netherlands already complies with the logic of the upcoming EU change. No changes are expected other than formalizing the requirement. As of 2025, the Netherlands is even exploring further easing of VAT registration (“single VAT registration” principle), consistent with this philosophy. In 2028, under EU law, all Member States will adopt the Dutch-style approach, so the Netherlands is essentially a model here.

Poland

Implemented? Yes (partially). Poland’s adoption of Article 194 is conditional on the supplier’s registration status in Poland. If a foreign supplier is not Polish VAT-registered, reverse-charge will apply on B2B sales; if they are registered, they must charge VAT.

Scope & Application: Polish VAT Act (Art. 17(1) point 4) stipulates that when a taxable person not established in Poland makes a supply of goods or services in Poland to a taxable person established in Poland, and the foreign supplier is not registered for VAT in Poland, the Polish customer becomes the person liable for the VAT. In practice:

A non-established company with no Polish VAT number selling goods in Poland to a Polish VAT payer – the invoice is without VAT and the Polish buyer self-assesses the VAT.

A non-established company providing, say, a spectacle in Poland (cultural service) to a Polish VAT-registered event organizer – the foreign supplier, if not registered in PL, doesn’t charge VAT; the Polish recipient accounts for it. Conversely, if the foreign company decides to register for VAT in Poland (or is forced to, e.g., due to some B2C activities), then any supplies it makes on Polish territory must include Polish VAT (the reverse-charge won’t be used because the supplier has a local VAT ID). This creates an interesting scenario where foreign companies sometimes choose not to register to benefit from the reverse-charge on their B2B sales.

Exclusions: Poland did not list particular types of supplies to exclude from Article 194; the main exclusion is if the supplier is registered. That said, if a foreign entity has a fixed establishment in Poland that participates in the supply, then that local FE is considered the supplier and must charge VAT (common interpretation EU-wide). Also, naturally, if the Polish customer is not a VAT-payer (or if the supply is to a consumer), then the foreign supplier must register and charge VAT, because reverse-charge cannot target a non-taxable person.

Other Polish measures: Poland, like Hungary, had various domestic reverse-charge applications (for example, for certain electronics and steel products) in the past, but since 2020 Poland moved many of those to its split payment mechanism. Those were separate from Article 194 and have been phased out or changed. Now, Poland primarily uses Article 194 for the foreign supplier scenario and Article 17(1) point 7 for specific domestic cases such as sales of real estate by debtors, etc.

Future Changes: Under the agreed EU changes effective July 2028, Poland will have to adjust its rules to allow reverse-charge in all cases of non-established suppliers selling to VAT-identified customers, even if the foreign supplier is VAT-registered in Poland. This means the current distinction based on registration status will go away – foreign suppliers can choose to use reverse-charge for B2B sales despite having a PL VAT number. Until then, no major changes are expected (Poland already practices the core of Article 194, just with that one condition). Polish VAT law will be updated to comply with the new uniform standard at the 2028 deadline.

Portugal

Implemented? Yes (with unique conditions). Portugal allows Article 194 reverse-charge, but imposes some specific conditions related to VAT registration and fiscal representation that are unique in the EU. The application depends on both supplier and customer’s VAT setup in Portugal.

Scope & Application: According to the Portuguese VAT Code (CIVA, Article 2(1)(g)), when a supplier is not established in Portugal, domestic VAT can be shifted to the customer in two scenarios: (1) if the supplier is not registered for VAT in Portugal, or (2) if the supplier is registered in Portugal but without having appointed a fiscal representative (the latter applies only to suppliers from the EU, as non-EU suppliers are generally required to have a fiscal rep). Simultaneously, the customer must be either (a) a taxable person established in Portugal, or (b) a taxable person not established in Portugal but who is VAT-registered in Portugal and has appointed a fiscal representative39 40. In simpler terms:

If a foreign supplier with no establishment makes a sale in Portugal and hasn’t got a Portuguese VAT registration (i.e., is completely non-registered), the Portuguese reverse-charge kicks in (assuming the buyer meets the criteria).

If the foreign supplier does have a Portuguese VAT number but obtained it directly (because they are EU-based and didn’t need a fiscal rep), Portuguese law still allows reverse-charge in that case – since the supplier has no fiscal representative.

However, if a foreign supplier went through the process of appointing a fiscal representative in Portugal (usually required for non-EU companies to register), Portuguese law historically considered that scenario as one where the supplier should charge VAT, not the customer. Likewise if the customer is foreign and directly VAT-registered (no rep), that customer wouldn’t qualify to self-assess under the old rule. Essentially, Portugal’s rule tried to encourage that at least one party (either the foreign supplier or a foreign customer) have a fiscal representative if reverse-charge is to be used.

Practical impact: Many EU companies who trade in Portugal simply do not register at all (thus fulfilling supplier not registered) and sell to Portuguese VAT businesses – the Portuguese customer pays the VAT (common). Non-EU companies, to avoid Portuguese VAT obligations, often rely on selling to established Portuguese businesses (the established buyer triggers it). But if, say, a non-EU company was forced to register with a rep (to make some B2C sales perhaps), any B2B sales it makes might technically fall outside the reverse-charge by the letter of law (since the supplier has a rep, making them ineligible for this simplification). This complexity has made Portuguese rules a bit confusing.

Customer condition: As stated, the customer must either be established in Portugal or, if not, then VAT-registered in Portugal with a fiscal representative. A Portuguese company obviously qualifies. A foreign company that directly got a Portuguese VAT number (no rep) originally did not qualify, meaning a foreign buyer couldn’t benefit from reverse-charge unless they had a rep. (Post-2028, this nuance will disappear.)

Summary: Portugal’s implementation is conditional but covers goods and services broadly as long as those conditions are met. So a foreign supplier of goods in Portugal can avoid registration if the Portuguese buyer is established (the usual case)41. If a foreign supplier has a Portuguese VAT number via direct reg, ironically they could still avoid charging VAT because they have no rep – Portuguese rules would let reverse-charge apply (that’s scenario (2) above).

Official guidance: Portuguese Tax Authority documents reflect these rules and often advise foreign businesses that if they do not wish to register, ensure the customer is established and accounts for the tax.

Future Changes: Portugal will have to simplify and liberalize these rules by 2028 due to the EU directive changes. The forthcoming standard will require that any foreign supplier (established abroad) selling to any Portuguese VAT-identified customer can use reverse-charge, with no additional conditions about reps or establishment42. This will override Portugal’s current stipulations. In other words, whether or not a foreign company or its customer has a fiscal representative will no longer matter – the reverse-charge will be available as long as the buyer has a Portuguese VAT number. Portugal will amend Article 2(1)(g) to remove the rep conditions at that time. Until then, the current conditional approach remains.

Romania

Implemented? Yes (fully). Romania applies Article 194 in a broad manner. Romanian law (Tax Code Art. 307) shifts VAT liability to the customer for all domestic supplies by non-established suppliers to VAT-registered persons.

Scope & Application: If a supplier is not established in Romania and makes a taxable supply in Romania to a person registered for VAT in Romania, then by Romanian law the customer is liable for the VAT. This covers all goods and services supplied in Romania by foreign businesses, with no special exceptions listed. Examples:

A Turkish company sells goods from a Romanian warehouse to a Romanian distributor – the Turkish company issues an invoice without Romanian VAT, and the Romanian distributor accounts for output VAT (and claims it back simultaneously if entitled).

An Austria-based company provides installation services in Romania for a Romanian factory – no Romanian VAT is charged by the Austrian firm; the factory self-assesses the VAT. In each case, because the supplier has no Romanian establishment, Romania makes the buyer the taxpayer for VAT.

Conditions: The Romanian customer must have a Romanian VAT registration (either as a normal VAT payer or as a person identified for VAT). If the Romanian customer is, say, a small company not registered for VAT (below threshold), then this mechanism cannot apply and the foreign supplier would need to register in Romania to charge VAT.

No unique deviations: Romania’s application doesn’t impose additional requirements like fiscal reps or specific sectors – it’s a straightforward transposition of Article 194. In fact, Romania is an example often cited for fully embracing the reverse-charge option to simplify life for foreign businesses.

Additional info: Romania also has other reverse-charge measures (e.g. for cereals, scrap, energy trading, etc.), but those are separate and apply to domestic transactions as anti-fraud tools. The non-established supplier rule is simply a blanket one in Romania. Often foreign businesses trading with Romanian companies are told to put a note on the invoice “TVA datorată de beneficiar, conform art. 307 Codul Fiscal” meaning “VAT due by customer per Art. 307 of Tax Code.”

Future Changes: Romania’s approach already aligns with the coming EU requirement. There are no known planned changes except to formally shift from “may” to “shall” in the legal text by 2028. One slight adjustment might be clarifying that even if a foreign supplier is registered in Romania (but with no establishment), they could still choose to use reverse-charge – currently, if a foreign supplier voluntarily registered, Romanian officials might expect them to charge VAT. After 2028, even those situations will allow reverse-charge at the supplier’s option. But practically, Romania has long encouraged the reverse-charge usage, so minimal change is needed.

Slovakia

Implemented? Yes (fully). Slovakia has recently moved towards a broad application of Article 194. Slovak VAT law (§69(2) of the VAT Act) specifies that the reverse-charge applies to all supplies of goods or services in Slovakia made by foreign entities to VAT-registered persons.

Scope & Application: If a supplier is not established in Slovakia and provides any taxable goods or services there to a Slovak VAT payer, the Slovak customer must pay the VAT (reverse-charge). This rule captures essentially all B2B transactions with a foreign supplier. For example:

A Czech company sells goods from a stock in Slovakia to a Slovak retailer – the Slovak retailer self-charges the Slovak VAT (the Czech company doesn’t need a SK VAT number in that scenario).

A US firm conducts training services in Slovakia for a Slovak company – the US firm invoices without VAT and the Slovak company accounts for the VAT. These outcomes are per Slovak law and tax authority guidance, which has been updated to clarify the broad use of reverse-charge for non-residents.

Conditions: The Slovak customer must be a person registered for VAT in Slovakia (either a domestic taxable person or a foreign taxable person with a Slovak VAT number). The law uses the term “VAT payer”. If the customer is not a VAT payer, then the mechanism wouldn’t apply and the foreign supplier would have to register in SK.

Update: In earlier years, Slovakia’s implementation had some ambiguity (hence older references saying “TBC”). However, as of 2022/2023, Slovakia has confirmed the broad application. The tax authorities in 2025 issued guidance reinforcing that any supply by a non-established to an established taxable person falls under reverse-charge. There was an exception for supplies to public authorities not registered for VAT (then the foreign supplier must register), but in B2B commerce, virtually everything goes through reverse-charge now.

Other reverse-charge: Slovakia, like others, also uses reverse-charge for domestic supplies prone to fraud (like construction services, certain agricultural goods, etc.), but those are separate provisions (and interestingly largely overlap with when the supplier could be local too).

Future Changes: Slovakia is effectively in line with the 2028 EU mandate already. No major changes are expected apart from formally adopting the mandatory language. Slovakia’s recent clarifications indicate it is prepared for the “Single VAT Registration” era where foreign businesses won’t need local numbers for B2B sales.

Slovenia

Implemented? Yes (fully). Slovenia’s VAT law (Article 76 ZDDV-1) implements Article 194 in a straightforward way: if the supplier is foreign, the local buyer handles the VAT. This applies to all supplies to VAT-registered customers.

Scope & Application: For any taxable supply of goods or services in Slovenia by a supplier not established in Slovenia, where the supply is made to a person registered for VAT in Slovenia, the Slovenian customer is liable for the VAT. In practice, this means foreign companies do not charge Slovenian VAT on B2B sales; the obligation shifts to the buyer. Examples:

A Croatian company sells products within Slovenia to a Slovenian distributor – no VAT is charged by the Croatian seller; the distributor computes the Slovenian VAT on that purchase in its VAT return.

An Italian firm provides repair services on machinery in Slovenia for a Slovenian factory – the Italian firm invoices net, the factory self-charges the VAT. This covers essentially all cases as long as the supplier doesn’t have a Slovenian establishment.

Conditions: The Slovenian customer must be a VAT-registered entity in Slovenia. If the customer is not, then the foreign supplier would need to register. Also, if the foreign supplier operates through a fixed establishment in Slovenia, then that local establishment is considered the supplier and must charge VAT (so Article 194 doesn’t apply in that case, per general rule).

No notable exceptions: Slovenia did not carve out specific transaction types; it implemented the optional provision almost verbatim. As a result, foreign businesses rarely need a Slovene VAT registration for B2B dealings.

Comparison: This approach is similar to Romania’s and the Netherlands’, representing a full adoption.

Future Changes: Slovenia is already aligned with the upcoming EU universal rule. No changes anticipated except formal ones. By 2028, it will continue with the same approach, simply under a mandatory regime rather than optional.

Spain

Implemented? Yes (fully). Spain employs Article 194 broadly. Spanish VAT law (Ley IVA, Article 84.1.2º) makes most supplies by non-established suppliers subject to reverse-charge, with minimal restrictions.

Scope & Application: If a taxable person not established in Spain carries out a supply of goods or services in Spain to a VAT-registered person in Spain, Spanish law generally makes the recipient the taxpayer for VAT. This means:

A non-established supplier (no Spanish establishment) doesn’t charge Spanish VAT on B2B sales; the Spanish customer self-assesses it.

It explicitly does not matter whether the foreign supplier is VAT-registered in Spain or not – the key is that the supplier lacks a fixed establishment in Spain43 44. So even if a foreign company took a Spanish VAT number (perhaps to make some zero-rated intra-EU supplies or such), for its domestic B2B sales it would typically issue invoices under reverse-charge (provided it has no Spanish branch).

Goods and services: All types of goods are included (if located in Spain at the time of supply). Spain even uses reverse-charge for supplies of immovable property by foreign persons (though such transactions are less common). Services are covered for cases where the service is taxable in Spain – many B2B services default to Article 196 (which also makes the customer liable). For those that don’t (like services physically performed in Spain to a Spanish customer), Article 194 picks them up.

Conditions: The Spanish customer must be a taxable person with a Spanish VAT number. Spanish law’s phrasing is “cuando el destinatario esté establecido en el TAI” or effectively, the recipient is a business who is VAT registered. It actually covers recipients established or simply identified for VAT in Spain. So even foreign entities with a Spanish VAT number could count as recipients who must self-assess. If the customer is not VAT-registered (e.g., a consumer or exempt entity), then the foreign supplier has to register and charge VAT – reverse-charge won’t apply.

Notable points: Spain’s rule explicitly says it’s irrelevant if the customer is established or not in Spain, as long as they have a Spanish VAT identification 45. That differs from Italy or Belgium’s older approach and matches the intended 2028 standard. So Spain is quite forward-leaning here.

No major exceptions: One small exclusion in Spain: supplies by non-established suppliers to Spanish VAT-group members might have nuance, but generally they still apply reverse-charge. Also, if a non-established supplier sells goods to a Spanish company that is under the “simplified regime” (like a flat-rate farmer scheme), Spanish law has special handling, but those are edge cases. Essentially, any normal B2B scenario uses reverse-charge.

Invoice: The foreign supplier should include a note on the invoice such as “Operación sujeta a inversión del sujeto pasivo (artículo 84.Uno.2º Ley IVA)” indicating reverse-charge.

Future Changes: Spain’s framework is already in line with the coming mandatory rule, as it imposes no extra conditions beyond “client has VAT number”. No changes are foreseen until 2028; at that time, Spain will simply formalize this as an obligation (whereas currently it’s by national choice). Foreign businesses will continue to benefit from Spain’s reverse-charge approach.

Sweden

Implemented? Yes (fully). Sweden adopts Article 194 broadly for both goods and services. The Swedish VAT Act (Mervärdesskattelagen, e.g. Chapter 1 Section 2) provides that if a supplier is foreign, the VAT can be reversed to the buyer.

Scope & Application: For any taxable supply in Sweden by a supplier without a established place of business in Sweden, where the supply is made to a taxable person (business) in Sweden, the Swedish buyer is responsible for the VAT. In effect:

Foreign companies do not charge Swedish VAT on B2B sales; Swedish business customers self-report it.

This covers goods located in Sweden sold by foreign vendors to Swedish VAT-registered entities, and services performed/delivered in Sweden by foreign vendors to Swedish VAT-registered entities.

Example: A Norwegian company sells a batch of goods from a stock in Sweden to a Swedish retailer – the invoice has no VAT, and the Swedish retailer accounts for output VAT at 25% and claims it back in the same return if entitled. Or a UK firm organizes a conference in Sweden for a Swedish company – no VAT charged by the UK firm; the Swedish company does reverse-charge on that expense.

Conditions: The Swedish customer must be registered for VAT in Sweden (a “taxable person” likely means one who is or should be VAT registered). If a foreigner sells to a non-registered Swedish customer, then yes, the foreign supplier must register to handle the VAT.

No unusual restrictions: Sweden’s implementation has no extra quirks. If the foreign supplier has a fixed establishment in Sweden involved in the supply, then the supplier isn’t considered foreign for that supply (so it would charge VAT normally). Barring that, Sweden’s rule is straightforward.

Other info: Sweden also has several domestic reverse-charge rules for specific sectors (like construction services and scrap) but those overlap with Article 194 when the supplier is foreign or even when local. The key difference is those can apply even B2B locally to fight fraud. However, for a foreign supplier scenario, the general rule already covers it.

Future Changes: Sweden’s practice already meets the upcoming EU requirements. There are no indications of any change needed apart from adopting the mandatory language. By 2028, Sweden will formally “shall allow” what it currently “may allow,” with essentially no operational difference.

References to National Legislation/Guidance:

Austria: VAT Act 1994, §19 and Ministry of Finance “Reverse-Charge Guidelines” (explaining foreign services and assembled goods are reverse-charged; event admissions excluded)46 47.

Belgium: Belgian VAT Code, Article 51 §2, 5° (Autoliquidation for supplies by foreign taxable persons)48; Royal Decree No. 1, Articles 20–21 (further rules on reverse-charge invoicing).

Bulgaria: VAT Law, Article 82(2) (liability of recipient when supplier is non-resident, covering services, installation goods, and energy)49 50.

Croatia: VAT Act (Zakon o PDV), Article 75(3) (customer tax liability if supplier not established/not registered in HR – implied in tax guidance).

Cyprus: VAT Law of 2000 (as amended), Section 11 and 12 (certain supplies by non-residents – services, installed goods – tax payable by recipient).

Czech Rep.: VAT Act (Act No. 235/2004), §108(1)(c) (reverse charge for supply by person not established and not registered in CZ, to VAT payer).

Denmark: VAT Act (Momsloven), Section 46(1) (lists instances of reverse charge: e.g. goods with installation by foreign supplier, energy supplies).

Estonia: VAT Act, Section 44(5) (if supplier has no establishment and not registered, customer is VAT payer).

Finland: VAT Act (Arvonlisäverolaki), Section 9 (liability of buyer if seller has no fixed establishment in Finland and not VAT-registered).

France: CGI (Code Général des Impôts), Article 283(2) (reverse-charge for supplies by persons not established in France; customer must have French VAT number).

Germany: UStG (VAT Act), §13b (extensive list including para.5 for services by foreign suppliers, para.2 for specific goods like installation, etc. that shift tax to recipient).

Greece: VAT Code (Law 2859/2000), Article 35 (no general provision analogous to 194; foreign suppliers treated same as domestic – must register).

Hungary: VAT Act (Act CXXVII of 2007), Section 140-142 (defines domestic RC cases: foreign supplier scenarios and sector-specific cases; e.g. construction, etc.).

Ireland: Value-Added Tax Consolidation Act 2010, Section 12(1) and 16 (reverse charge on taxable supplies by persons not established in the State, with Regulations detailing construction and gas/electricity cases). Irish Revenue VAT Guide (Tax and Duty Manual on Reverse Charge).

Italy: DPR 633/72 (Italian VAT Decree), Article 17(2) (tax payable by recipient for supplies by non-resident without Italian establishment).

Latvia: VAT Law (2004), Section 85 & 86 (if supplier not registered in Latvia, purchaser is tax liable; specific mention in regs for services from non-established).

Lithuania: Law on VAT (2002 VIII-567), Article 95(2) (when supplier not established in LT, an established taxable recipient becomes liable for VAT).

Luxembourg: VAT Law (La loi TVA mod. 2007), Article 51(1)(a) and Article 51bis (limited to gas, electricity – introduced reverse charge; general rule absent pre-2028).

Malta: VAT Act (Chapter 406), Article 20(2) and 21(1) (recipient becomes liable for tax on supplies by non-residents in certain cases – essentially services). Malta Commissioner for Revenue Guidelines on Reverse Charge (explains only services qualify).

Netherlands: Wet op de Omzetbelasting 1968, Article 12(3) and Implementation Decree, Article 24b (reverse-charge for supplies by entrepreneurs not established in NL to those who are VAT-entrepreneurs in NL). Dutch Tax Administration guidance “BTW verlegd” (confirms broad use).

Poland: VAT Act (Ustawa o VAT), Article 17(1)(4) (tax obligation for buyer when supplier is not established and not registered in PL). Polish Ministry of Finance instructions (informing foreign businesses of this simplification).

Portugal: CIVA (Código do IVA), Article 2(1)(g) (defines cases for reverse charge: non-established supplier without registration or without rep; and conditions on customer). Portuguese Tax Authority official commentary on Article 194 implementation (Despatch 15.518/2008).

Romania: Fiscal Code (Law 227/2015), Article 307 (the reverse-charge for any supplier not established in RO, to a person registered for VAT in RO). ANAF Guidelines have a section on reverse-charge for non-residents.

Slovakia: VAT Act (Law 222/2004 Z.z.), §69(2) (customer is taxpayer if supplier has no seat or establishment in SK and customer is registered for VAT). Financial Directorate guidance in 2022 reiterated this broad rule.

Slovenia: ZDDV-1 (VAT Act), Article 76 (when supplier is a taxable person not established in Slovenia, VAT is due by the customer if they have a Slovenian VAT number).

Spain: Ley 37/1992 del IVA, Artículo 84.One.2º e) and f) (reverse-charge for operations by non-established suppliers where recipient is empresario/profesional with Spanish NIF-IVA). AEAT (Spanish Tax Agency) publishes detailed guidance on inversion del sujeto pasivo including these cases.

Sweden: Mervärdesskattelagen (1994:200), Chapter 1 §2 and Chapter 6 §2 (if seller is foreign without a fixed establishment in SE, the buyer is tax liable, provided buyer is VAT registered). Swedish Tax Agency guide “VAT handling for foreign companies” covers this.

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