Questioner’s goods are produced in EU countries B and C. Goods from EU country B to Scandinavian customers are sent via EU country C and Denmark. Goods from EU country C are sent via Denmark. In connection with transport to other Scandinavian countries, there is a temporary stop of very short duration in Denmark. After the goods arrive in Denmark, the goods are immediately forwarded to the customers in question in Scandinavia. The arrival of the goods to Denmark and the forwarding to the end customer will often take place on the same day. When the goods are shipped from EU country B or EU country C, the goods are finished, packaged and marked with the end customer’s name and address.
Contrary to questions, the Tax Council found that despite the stops in EU country C and Denmark, respectively stopped in Denmark, there is only a transport of the goods from EU country B and EU country C to customers in the other Scandinavian countries. In this connection, the Tax Council emphasized that no further work is carried out on the goods in Denmark, that the temporary stops in Denmark are made solely for logistical reasons, and that the final buyer has already been identified at the time the goods are transported from EU country B or EU country C, and that the stay / interruption of transport in Denmark is already planned at the time when the goods are shipped from EU country B and EU country C, respectively.
Conversely, the Tax Council found that the goods to Norway can not be considered exported from Denmark to Norway, and that the goods to other Scandinavian countries according to the rules on EU trade can not be considered delivered from Denmark to the other Scandinavian countries. Deliveries must instead be considered to take place directly from EU country B or EU country C to Norway or the other Scandinavian countries.
Source: skat.dk
