The transport of goods to a non-EU country may be zero-rated in so far as those services are provided directly to the consignor or the consignee of the goods.
Comments: This is a quite strict interpretation of the scope of that exemption. Where such transport is supplied to a person other than the exporter or the acquirer out of the EU, the zero-rate may not be relied upon. That is likely to affect the VAT regime applied to sub-contracted activities inter alia in the logistic sector.
Export Sales : What About the Time-Limit for Dispatch of Goods Leaving the European Union ?
Article 146 – Exemptions on exportation – Article 131– Conditions laid down by Member States – National legislation requiring that property intended to be exported leave the customs territory of the European Union within a fixed period of 90 days after supply)
Articles 146(1) and 131 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax must be interpreted as precluding national legislation under which, in the context of a supply for export, goods intended to be exported from the European Union must have left the territory of the European Union within a fixed period of three months or 90 days following the date of supply, where merely exceeding that time‑limit results in the definitive loss for the taxable person of the right to exemption in relation to that supply.