Official Journal of the European Union

C 213/12

(Case C-33/16) (<span class="super note-tag">1</span>)

((Reference for a preliminary ruling - Taxation - Value added tax - Directive 2006/112/EC - Article 148(d) - Exemption - Supply of services to meet the direct needs of vessels used for navigation on the high seas - Loading and unloading of cargo by a subcontractor on behalf of an intermediary))

(2017/C 213/13)

Language of the case: Finnish

Referring court

Parties to the main proceedings

Intervening party: Veronsaajien oikeudenvalvontayksikkö

Operative part of the judgment

1.Article 148(d) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax must be interpreted as meaning that loading and unloading of cargo are services supplied for the direct needs of the cargo of the vessels referred to in Article 148(a) thereof.

2.Article 148(d) of Directive 2006/112 must be interpreted as meaning that, first, not only supplies of services concerning loading or unloading cargo onto or from a vessel covered by Article 148(a) of that directive which take place at the end of the commercial chain of such a service may be exempt, but also supplies of services made at an earlier stage, such as services supplied by a subcontractor to an economic operator which then re-invoices them to a freight forwarder or transporter and, second, services for loading and unloading of cargo supplied to the holders of that cargo, such as the exporter or importer may also be exempt.

Language of the case: Finnish

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(<span class="super note-tag">1</span>) OJ C 111, 29.3.2016.