VAT exemption and transportation for exportation undertaken by subcontractors

In a jugdment dated June 29th, 2017, the CJEU stated that service provisions (transportation of goods and ancillary services) to a third country were not VAT-exempt when these services were not directly provided to the sender or to the recipient of the goods, but to the main carrier by a subcontractor.

More precisely, the CJEU rules that the existence of a direct link (as provided for in article 146, 1-e of the VAT directive) between service provisions and imports or exports of goods implies that related service provisions contribute to the actual completion of an export or an import, but also that these services be directly provided to the importer, the exporter or the recipient of the goods.