How do I install the Vat Place Of Supply Master skill?

Run npx skillmds@latest add openaccountants/vat-place-of-supply-master in your terminal (requires Node.js), paste this page's agent-chat prompt into Claude, Cursor, or any MCP-connected agent, or download the SKILL.md file and copy it into your agent's skills directory.

What does the Vat Place Of Supply Master skill do?

> The definitive place-of-supply reference for cross-border VAT on services and goods. Use when the user asks about: place of supply, where is VAT due, which country's VAT, Art 44, Art 45, B2B place of supply, B2C place of supply, immovable property VAT, transport VAT, electronically supplied services place of supply, distance selling, chain transactions, triangulation, OSS decision tree, IOSS, intra-EU supply, import VAT, Art 47, Art 48, Art 53, Art 55, Art 56, Art 58, Art 31, Art 32, Art 33, Art 36a, US sales tax nexus, Australian GST on imports, India OIDAR, Japan consumption tax, freelancer cross-border VAT, "where do I charge VAT", or any question about determining the correct country for VAT/GST on a cross-border transaction. It is listed under AI & ML on SkillMD.

Is Vat Place Of Supply Master safe to use?

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Which AI agents work with Vat Place Of Supply Master?

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Is Vat Place Of Supply Master free to use?

Yes. Installing skills from SkillMD is free. This skill is licensed under AGPL-3.

Who published Vat Place Of Supply Master?

openaccountants (@openaccountants) published this skill. Their other Agent Skills are listed on their SkillMD profile.

Vat Place Of Supply Master by openaccountants

Name: Vat Place Of Supply Master
Author: openaccountants

VAT Place of Supply — Master Reference for Cross-Border Transactions

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Disclaimer: This skill provides general guidance on VAT/GST place-of-supply rules. These rules are complex, jurisdiction-specific, and subject to change. Consult a qualified indirect tax advisor before taking positions on VAT obligations.

Skill Metadata

Field	Value
Jurisdiction	EU (all 27 member states) + non-EU comparison
Primary Legislation	Council Directive 2006/112/EC, Articles 31–59c
Supporting Legislation	Council Implementing Regulation (EU) No 282/2011
Scope	Determining the correct country for VAT on cross-border supplies of goods and services
Contributor	OpenAccountants
Validation Date	May 2026
Skill Version	1.0
Cross-references	`eu-reverse-charge.md`, `eu-oss-digital.md`, `non-eu-export-services.md`, `cross-border-vat-gst.md`

Section 1: General Rules for Services

Legislation: VAT Directive 2006/112/EC, Articles 44 and 45.

There are two basic rules. Every service starts here before checking exceptions.

Article 44 — B2B General Rule [T1]

Element	Rule
Customer	Taxable person acting as such (business with VAT number)
Place of supply	Where the customer is established (or has a fixed establishment receiving the service)
VAT consequence	Supplier invoices without VAT; customer self-assesses under reverse charge (Art 196 within EU)
Verify	Customer's VAT number via VIES before zero-rating

Article 45 — B2C General Rule [T1]

Element	Rule
Customer	Non-taxable person (private individual)
Place of supply	Where the supplier is established (or has a fixed establishment from which the service is supplied)
VAT consequence	Supplier charges their own country's VAT rate
Exception	Numerous special rules override Art 45 for specific service types (see Section 2)

Quick Reference

Scenario	Place of Supply	Who Accounts for VAT
B2B general service	Customer's country	Customer (reverse charge)
B2C general service	Supplier's country	Supplier

Section 2: Special Rules for Services

These override the general rules above. Always check whether an exception applies before defaulting to Art 44/45.

2.1 Immovable Property — Article 47 [T1]

Rule	Detail
Applies to	Valuation, estate agency, legal services related to property, construction, accommodation, property management, architect services
Place of supply	Where the property is located — regardless of B2B/B2C and regardless of where supplier or customer is
Practical impact	A German architect designing a building in Portugal must charge Portuguese VAT (or register there), even if the client is in Ireland
Common trap	Freelancers forget that remote design work for foreign property still follows this rule

2.2 Passenger Transport — Article 48 [T1]

Rule	Detail
Place of supply	Where the transport takes place, proportional to distances covered in each country
B2B/B2C	Same rule applies to both
Example	A bus journey from Belgium through Luxembourg to Germany: VAT is split proportionally across all three countries

2.3 Goods Transport (B2C only) — Article 49 [T2]

Rule	Detail
Place of supply	Where the transport takes place, proportional to distances
B2B	Art 44 applies instead (customer's country)
B2C intra-EU	Place where transport begins, unless transport is between two member states — then destination

2.4 Cultural, Artistic, Sporting, Scientific, Educational, Entertainment Events — Articles 53–54 [T2]

Scenario	Article	Place of Supply
B2B — admission to an event	Art 53	Where the event physically takes place
B2C — admission and related services	Art 54	Where the event physically takes place
B2B — services other than admission (e.g., organising, production)	Art 44	Customer's country (general rule)

Key distinction: "Admission" means the right to attend. Organising or sponsoring an event for a business client follows the general B2B rule (Art 44), not the event location rule.

ECJ case C-647/17 (Srf konsulterna): A seminar involving active participation for a business client is a B2B service under Art 44, not "admission" under Art 53.

2.5 Restaurant and Catering Services — Article 55 [T1]

Rule	Detail
Place of supply	Where the services are physically carried out
On board transport	See Art 57 — place of supply = point of departure within EU
B2B/B2C	Same rule for both

2.6 Short-Term Hire of Transport — Article 56 [T1]

Hire Duration	Place of Supply
Short-term (≤30 days; ≤90 days for vessels)	Where the means of transport is put at the customer's disposal
Long-term B2B	Customer's country (Art 44)
Long-term B2C	Supplier's country (Art 45), except pleasure boats = where put at disposal if supplier established there

2.7 Electronically Supplied Services, Telecoms, Broadcasting (B2C) — Article 58 [T1]

Rule	Detail
Applies to	SaaS, downloads, streaming, e-books, online courses (pre-recorded), cloud hosting, telecoms, broadcasting — B2C only
Place of supply	Where the customer is established / resides
B2B	Art 44 applies instead (customer's country, reverse charge)
EUR 10,000 threshold (Art 59c)	EU-established sellers below €10,000 total cross-border B2C digital sales may charge home-country VAT
Non-EU sellers	No threshold benefit; must always charge destination-country rate
Compliance	Use OSS (One-Stop Shop) to report across all EU countries from a single registration

2.8 "Listed Services" to Non-EU Consumers (B2C) — Article 59 [T1]

Certain services supplied B2C to a person outside the EU are taxed where the customer is — making them outside the scope of EU VAT:

Intellectual property / copyright licensing
Advertising
Consulting, legal, accounting, engineering
Data processing, information supply
Banking, financial, insurance services
Staff supply
Hiring of movable tangible property (except transport)
Telecoms, broadcasting, electronically supplied services

If the B2C service is NOT on this list (e.g., personal services, cleaning, yoga instruction): place of supply remains the supplier's country under Art 45, even if the consumer is outside the EU.

Section 3: Rules for Goods

3.1 Domestic Supply — No Transport (Article 31) [T1]

Rule	Detail
Place of supply	Where the goods are located at the time of supply
Example	Goods sold in a German shop to a walk-in customer: German VAT

3.2 Goods Dispatched or Transported (Article 32) [T1]

Rule	Detail
Place of supply	Where the goods are located when dispatch or transport to the customer begins
Example	German warehouse ships goods to a German customer: place of supply = Germany
Exception	Distance selling rules (Art 33) and installation/assembly (Art 36) override this

3.3 Intra-EU Distance Selling (Article 33) [T1]

Rule	Detail
What	Goods sold to consumers (B2C) or non-VAT-registered entities in another EU country
Place of supply	Where dispatch or transport ends (customer's country)
EUR 10,000 threshold (Art 59c)	EU sellers below €10,000 total cross-border B2C goods + digital services may treat place of supply as origin country
Above threshold	Must charge destination-country VAT rate
Compliance	Use Union OSS to report all intra-EU distance sales from one registration
Post-2021 change	Individual country thresholds (€35,000/€100,000) replaced by single €10,000 EU-wide threshold

3.4 Imports from Outside the EU (Article 30/60-61) [T1]

Rule	Detail
Place of importation	The EU member state where goods enter the EU (Art 60)
Suspensive arrangements	If goods are placed under customs warehousing or transit, importation occurs where goods leave that arrangement (Art 61)
VAT due	At importation, by the importer — collected by customs
IOSS alternative	For goods ≤€150 sold B2C, use Import One-Stop Shop to collect VAT at point of sale

3.5 Installation or Assembly (Article 36) [T1]

Rule	Detail
Place of supply	Where the goods are installed or assembled
Example	German manufacturer ships and installs machinery in a French factory: place of supply = France

3.6 Chain Transactions (Article 36a) [T1]

Introduced by Directive (EU) 2018/1910 to simplify chain (successive) supplies:

Element	Rule
Scenario	Goods supplied A → B → C, shipped directly from A to C across EU borders
Transport attributed to	The supply to the intermediary operator (B)
Intermediary operator	A supplier in the chain (other than the first) who dispatches or arranges transport
Exception	If B communicates to A the VAT number issued by the dispatch member state, transport is attributed to B's supply to C
Effect	Only one supply in the chain is the intra-EU zero-rated supply; the other is a domestic supply

Simplified triangulation (Art 141): In a three-party chain A (MS1) → B (MS2) → C (MS3), B can avoid registering in MS3 if all conditions of Art 141 are met. B issues an invoice with "reverse charge" and C self-assesses VAT in MS3.

Section 4: OSS / IOSS Decision Tree

When to register for One-Stop Shop

START: Do you sell goods or digital services B2C to consumers in other EU countries?
│
├─ NO → OSS not needed
│
├─ YES → Are you an EU-established business?
│   │
│   ├─ YES → Do your total cross-border B2C sales (goods + digital services)
│   │         exceed EUR 10,000/year?
│   │   │
│   │   ├─ NO → You MAY charge home-country VAT. OSS optional.
│   │   │        (But you can opt in to OSS voluntarily.)
│   │   │
│   │   └─ YES → You MUST charge destination-country VAT.
│   │             Register for UNION OSS in your home country.
│   │
│   └─ YES (established in >1 EU country) → EUR 10,000 threshold does NOT apply.
│         Register for Union OSS.
│
└─ YES → Are you a NON-EU business?
    │
    ├─ Selling digital services / telecoms / broadcasting B2C →
    │   Register for NON-UNION OSS in any EU country of choice.
    │   No threshold benefit. Always charge destination rate.
    │
    └─ Selling goods from outside EU, consignments ≤EUR 150 →
        Register for IOSS (Import One-Stop Shop).
        Collect VAT at checkout. Goods enter EU VAT-paid.
        Note: From 1 July 2026, EUR 3 flat customs duty also applies.

OSS Comparison Table

Scheme	Who	What	Filing
Union OSS	EU-established sellers	Intra-EU B2C distance sales of goods + B2C services in other EU states	Quarterly, home country
Non-Union OSS	Non-EU sellers	B2C digital/telecom/broadcasting services to EU consumers	Quarterly, any EU country
IOSS	Any seller (EU or non-EU)	Distance sales of imported goods ≤€150 to EU consumers	Monthly, home/chosen country

Section 5: Non-EU Rules Comparison

5.1 US Sales Tax Nexus

Aspect	US Rule
Tax type	Sales tax (state-level, not federal)
Place of supply equivalent	"Nexus" determines which state can tax you
Physical nexus	Office, warehouse, employee, or inventory in the state
Economic nexus (South Dakota v. Wayfair, 2018)	Most states: $100,000 in sales OR 200 transactions/year
Digital services	Taxability varies by state — SaaS taxable in ~25 states, not taxable in CA, GA, MO
No equivalent of reverse charge	Seller must collect and remit; no mechanism for buyer self-assessment in most states
Key difference from EU	No single national registration; must track nexus in 45+ states individually (or use automation like Stripe Tax, TaxJar, Avalara)

5.2 Australian GST on Imports

Aspect	Australian Rule
Threshold	AUD 75,000/year in supplies to Australian consumers
Digital services B2C	Non-resident must register for GST and charge 10%
Low-value goods (≤AUD 1,000)	GST applies at point of sale since July 2018
B2B	Reverse charge applies (Australian business self-assesses)

5.3 India OIDAR (Online Information and Database Access or Retrieval)

Aspect	Indian Rule
Applies to	Non-resident suppliers of OIDAR services to non-taxable Indian recipients (B2C)
Definition	Services delivered over the internet — substantially automated, minimal human intervention
Rate	18% IGST
Registration	Simplified registration under GST for non-resident OIDAR suppliers
B2B	Indian business self-assesses under reverse charge
Equalization Levy	Separate 2% levy on non-resident e-commerce operators (no global revenue threshold)

5.4 Japan Consumption Tax on Digital Services

Aspect	Japanese Rule
Rate	10% (8% reduced rate for food/beverages, not applicable to digital)
Non-resident digital services B2C	Must register and charge JCT regardless of revenue
B2B	Reverse charge applies for "specified services" received from abroad
Threshold	No de minimis for non-resident digital service providers to consumers
Invoice system	Qualified Invoice System (QIS) since October 2023 — registered invoices required for input tax credit

Comparison Summary

Feature	EU	US	Australia	India	Japan
Tax type	VAT	Sales tax	GST	GST + EL	JCT
B2B mechanism	Reverse charge	N/A	Reverse charge	Reverse charge	Reverse charge
B2C digital	Customer location	Nexus-based	Customer location	Customer location	Customer location
Single registration	OSS	No (per-state)	Single ATO reg	Single GST reg	Single NTA reg
Threshold (B2C digital)	€10,000 (EU sellers)	$100K/200 txn per state	AUD 75,000	Nil (simplified reg)	Nil

Section 6: Practical Decision Flowchart for Freelancers

"I'm in Country A, my client is in Country B, and I'm providing [service type]. What VAT applies?"

Step 1: Classify the Supply

Question	If YES	If NO
Are you selling goods (physical products)?	Go to Goods Flow (below)	Continue to Step 2

Step 2: Identify the Customer

Question	If YES	If NO
Is your client a business (with a VAT number)?	B2B → Go to Step 3	B2C → Go to Step 4

Step 3: B2B Service — Check Exceptions

Question	If YES	If NO
Is the service related to immovable property (Art 47)?	VAT where property is located	Continue
Is the service admission to an event (Art 53)?	VAT where event takes place	Continue
Is it short-term hire of transport ≤30 days (Art 56)?	VAT where vehicle put at disposal	Continue
Is it restaurant/catering (Art 55)?	VAT where performed	Continue
Is it passenger transport (Art 48)?	VAT proportional to route	Continue
None of the above?	→ Art 44 applies. Place of supply = client's country. Invoice without VAT. Client self-assesses (reverse charge in EU; self-assessment rules outside EU).

Step 4: B2C Service — Check Exceptions

Question	If YES	If NO
Is it an electronically supplied service, telecoms, or broadcasting (Art 58)?	VAT where consumer is located. Use OSS if selling into EU.	Continue
Is the service related to immovable property (Art 47)?	VAT where property is located	Continue
Is it admission to an event (Art 54)?	VAT where event takes place	Continue
Is the consumer outside the EU and is the service on the Art 59 list?	Outside scope of EU VAT	Continue
None of the above?	→ Art 45 applies. Place of supply = YOUR country. Charge your domestic VAT rate.

Goods Flow

Question	If YES	If NO
Are you shipping goods to a consumer in another EU country?	Distance selling (Art 33). Above €10,000 threshold → destination VAT. Use Union OSS.	Continue
Are you shipping goods from outside the EU to EU consumers, value ≤€150?	Use IOSS. Collect destination VAT at checkout.	Continue
Are goods installed/assembled at customer location (Art 36)?	VAT where installed	Continue
Standard domestic or B2B intra-EU supply?	Art 31/32 (origin) or intra-EU zero-rated supply + acquisition tax in destination

Common Freelancer Scenarios

You are in...	Client is in...	Service	Result
Germany	France	Web development (B2B)	Art 44. No German VAT. French client reverse-charges at 20%.
Germany	France	Web development (B2C)	Art 45. Charge German 19% VAT. (Not a digital service — bespoke human work.)
Germany	France	SaaS subscription (B2C)	Art 58. Charge French 20% VAT. Report via OSS.
Malta	US	Consulting (B2B)	Art 44. Place of supply = US. No Malta VAT. Outside scope.
Malta	US	Pre-recorded online course (B2C)	Art 58/59. Place of supply = US (outside EU). No Malta VAT. But check US sales tax nexus.
UK	Germany	Design services (B2B)	UK is outside EU. No UK VAT (outside scope). German client self-assesses under German domestic rules.
India	Australia	Software dev (B2B)	Zero-rated export under IGST. No IGST if LUT filed. Australian client reverse-charges GST.
US	EU consumers	SaaS product (B2C)	Must register for non-Union OSS. Charge each EU country's VAT rate. No threshold benefit.
France	Switzerland	Architecture for property in France	Art 47. Property in France → French VAT at 20%, regardless of client location.

PROHIBITIONS

NEVER default to Art 44 or Art 45 without checking the exceptions in Section 2.
NEVER assume that all B2C services to foreign consumers are outside the scope of VAT. Only Art 59 "listed services" shift to the consumer's country for B2C.
NEVER ignore the immovable property rule (Art 47). It overrides everything.
NEVER apply the €10,000 threshold to non-EU sellers — they must always charge destination-country VAT.
NEVER confuse "zero-rated" with "exempt." Zero-rated preserves input VAT recovery; exempt does not.
NEVER skip VIES verification before zero-rating an intra-EU B2B supply.
NEVER assume the same place-of-supply rules apply in all countries. Non-EU jurisdictions (US, Australia, India, Japan) have fundamentally different approaches.

Edge Cases

EC1 — Bespoke software vs. SaaS (ESS classification) [T2]

Situation: A developer builds custom software for a specific B2C client. Is this an electronically supplied service (Art 58)? Resolution: Custom software development with significant human intervention is NOT an ESS. It is a standard service under Art 45 (B2C) or Art 44 (B2B). Pre-packaged SaaS delivered automatically IS an ESS. Flag for reviewer if the degree of customisation is unclear.

EC2 — Remote worker creating PE risk [T2]

Situation: A UK freelancer works from Spain for 8 months serving UK clients. Does Spain become the "establishment" for place-of-supply purposes? Resolution: If the freelancer becomes established in Spain (fixed establishment under Art 11 of Implementing Regulation 282/2011), the place of supply of their B2C services may shift to Spain. B2B services under Art 44 are unaffected (place of supply = client's country). Flag for reviewer — tax residency and PE risk should also be assessed.

EC3 — Mixed digital and live service bundle [T2]

Situation: A course provider sells a package: pre-recorded videos (ESS) + live weekly coaching calls (not ESS) to an EU consumer. Resolution: If a single composite supply, the principal element determines classification. If independent supplies, each follows its own rules. Pre-recorded = Art 58 (customer location). Live coaching = Art 45 (supplier location). Flag for reviewer to determine whether composite or independent.

EC4 — Chain transaction with unknown intermediary role [T3]

Situation: A → B → C chain where goods ship directly from Poland to Portugal, but it is unclear whether B is the intermediary operator under Art 36a. Resolution: Escalate. The attribution of transport determines which supply is zero-rated (intra-EU) and which is domestic. Incorrect attribution can cause double taxation or VAT loss. Requires review of contractual arrangements and Incoterms.

Test Suite

Test 1 — B2B consulting, Germany to France

Input: German consultant invoices French company (valid FR VAT number) EUR 5,000 for strategy consulting. Expected: Art 44. Place of supply = France. No German VAT. Reverse charge. Supplier reports on ESL.

Test 2 — B2C yoga class (non-listed service), Malta to US consumer

Input: Maltese instructor provides a private in-person yoga session in Malta to a US tourist. EUR 100. Expected: Art 45. Not a listed service under Art 59. Place of supply = Malta. Charge Maltese VAT at 18%.

Test 3 — B2C SaaS, US company to French consumer

Input: US SaaS company sells a EUR 20/month subscription to a French consumer. Expected: Art 58. ESS B2C. Place of supply = France. Non-Union OSS required. Charge 20% French VAT.

Test 4 — Architect, property in another country

Input: Italian architect designs a villa in Greece for a German client (B2B). EUR 15,000. Expected: Art 47 (immovable property). Place of supply = Greece. Reverse charge does NOT apply under Art 196. Italian architect may need to register for Greek VAT.

Test 5 — Distance selling, below threshold

Input: Spanish e-commerce seller ships EUR 8,000 of handmade goods to consumers across 5 EU countries. Prior year was EUR 7,000. Expected: Below €10,000 threshold. May treat place of supply as Spain and charge Spanish VAT. OSS optional.

Test 6 — Distance selling, above threshold

Input: Same seller now has EUR 15,000 in cross-border B2C goods sales. Expected: Above threshold. Must charge destination-country VAT. Register for Union OSS.

Official Sources

EU VAT Directive (consolidated): https://eur-lex.europa.eu/eli/dir/2006/112
EC Place of Taxation guidance: https://taxation-customs.ec.europa.eu/taxation/vat/vat-directive/place-taxation_en
EU OSS portal: https://vat-one-stop-shop.ec.europa.eu
VIES VAT number validation: https://ec.europa.eu/taxation_customs/vies/
Implementing Regulation 282/2011: https://eur-lex.europa.eu/eli/reg_impl/2011/282
IOSS guidance (Irish Revenue): https://www.revenue.ie (search "IOSS")

Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. VAT rates, thresholds, and place-of-supply rules are subject to change. Always verify current rules with official sources and a qualified indirect tax advisor.

Data reflects 2025–2026 rules. OpenAccountants — open-source accounting skills for AI — info@openaccountants.com

Source: OpenAccountants — open tax Guides for AI, reviewed by named CPAs/CAs/EAs. Quality: source-cited draft. For always-current figures and named-accountant backing, connect the OpenAccountants MCP server (openaccountants-mcp).

Vat Place Of Supply Master

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