mr. J. el Khalfioui LL.M.

, in VAT

How far a VAT representative is liable for a client's unpaid VAT

On 8 July 2026, the EU General Court set out in Case T-356/25 how far a tax representative answers for a client's VAT. This matters to every business that uses a representative in another Member State, and to the representatives themselves.

The case

A Greek customs agent acted as tax representative of an Italian company that traded cellulose and stored goods in Greece. Under a power of attorney, she filed VAT returns and handled payments and customs formalities. After an inspection of the years 2020 to 2022, the Greek authority found unpaid VAT of EUR 3,344,061.47 and froze part of the bank deposits of both the company and the representative. She said that she had only filed returns and paid the tax due on them.

The ruling

The General Court drew a clear line between two articles of the VAT Directive.

Two further points follow. The same person cannot be liable under both articles. And it makes no difference whether the transaction ran under the client's home VAT number or under its number in the Member State where the VAT is due.

What to check

mr. J. el Khalfioui LL.M.

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