RR Donnelly Global Turnkey Solutions Poland supplied services related to the storage of goods to companies located inside and outside the EU. The Polish government considered that the services were liable to VAT in Poland because they were services related to immovable property and were subject to VAT in the place where the immovable property is located.
The issue was whether complex services related to the storage of goods are to be treated as services connected with immovable property. The Advocate General opined in February 2013 that the application of Article 47 required that the subject matter of the service was the use of specific immovable property, or that the service is one that is explicitly listed in Article 47.
In its decision issued on 27 June 2013 the ECJ agreed with the Advocate General’s opinion.
