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Reseller (taxed at its home) Final user (taxed at the plug) Source / no-sale handover
Audited against primary sources, June 2026. Charging is a supply of goods (CJEU C-282/22 and C-60/23, Digital Charging Solutions); the multi-step sale uses the commissionaire rule (Art. 14(2)(c)); each B2B leg to a reseller follows that reseller's country (Art. 38 taxable dealer, with Art. 39(2) as the fallback for non-dealer resellers, reverse charge via Art. 195 inside the EU); the one sale to whoever uses the electricity is taxed where it is consumed (Art. 39). A connectivity-only roaming hub supplies a B2B service taxed where its customer is established (Art. 44 + Art. 196). The party making the final taxed sale needs a VAT registration in each EU charging country until the ViDA OSS extension applies from 1 Jan 2027 (Directive 2025/516). Whether a lease or fleet company formally qualifies as an Art. 38 taxable dealer is unsettled. Organisations consuming electricity recover VAT via domestic deduction or the Art. 170 / Directive 2008/9 refund (minimums roughly €50/year, €400/quarter), with a valid invoice in the company name; private use by employees may trigger adjustments, and home-charging a company car is often non-recoverable (HMRC position, contested). UK charges sit under UK law: public charging 20% per HMRC, with a Feb 2026 tribunal (Charge My Street) finding 5% can apply to small top-ups, under appeal; home charging 5%. Rates are standard rates and illustrative; this is an explainer, not tax advice.