Doctrine by topic · DGT Observatory

Third Territory: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 16 rulings · 2014–2024

Current position

For an intra-Community acquisition to exist, the movement of goods must mandatory begin in a Member State of the European Union. If the goods originate from a third territory, the operation is classified as an import into the territory where the tax applies. In this case, the supplier does not make an exempt intra-Community delivery, and the recipient acts as the taxable person for the import.

The DGT's position remains constant in the definition of third territory and its distinction from the territory where VAT (IVA) applies. The rulings confirm that movements from third territories do not constitute intra-Community acquisitions, but rather imports. No doctrinal changes are observed, but rather a reiteration of the nature of the operations according to their origin.

Analysis based on 16 of 16 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

16

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact