Revenue Note for Guidance

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Revenue Note for Guidance

40. Special consideration rule, triangulation


This section covers the situation where an intra-Community acquisition (ICA) occurs both within the State and in the territory of another Member State as a consequence of section 32. Where this situation arises, VAT will be payable in the Member State to which the goods are actually delivered and, to avoid double taxation, VAT must be relieved in the other Member State. The rule in this section provides that the consideration for the ICA in the State is deemed to be nil where VAT is payable in the other Member State.



  • A trader in Ireland quotes his or her VAT registration number to obtain goods from France.
  • The goods are actually delivered to Germany.
  • The goods will be subject to VAT on the acquisition in Germany but there will also be a taxable acquisition in the State.
  • Once the Irish trader establishes that tax has been paid and accounted for in Germany the tax charge in Ireland will be cancelled so as to avoid double taxation.

Relevant Date: Finance Act 2020