Bundled, Integrated and Deemed - The Classification of Composite Supplies in Digital Services under EU VAT
(2026) HARN60 20261Department of Business Law
- Abstract
- The digitalisation of the economy has fundamentally challenged the application of the European Union’s (EU) value added taxation (VAT) law, regarding the classification of transactions involving multiple elements. Digital platforms frequently combine content delivery, payment processing, platform access and intermediation into integrated offerings, making it difficult to determine whether a transaction constitutes a single composite supply or multiple independent supplies. At the same time, the EU has specific deemed supplier regimes under which platforms may be treated as suppliers for VAT purposes, raising questions as to how these regimes interact with the traditional composite supply doctrine.
This thesis examines how the doctrine of... (More) - The digitalisation of the economy has fundamentally challenged the application of the European Union’s (EU) value added taxation (VAT) law, regarding the classification of transactions involving multiple elements. Digital platforms frequently combine content delivery, payment processing, platform access and intermediation into integrated offerings, making it difficult to determine whether a transaction constitutes a single composite supply or multiple independent supplies. At the same time, the EU has specific deemed supplier regimes under which platforms may be treated as suppliers for VAT purposes, raising questions as to how these regimes interact with the traditional composite supply doctrine.
This thesis examines how the doctrine of composite supplies applies to digital services under EU VAT law, and to what extent the application of deemed supplier regimes affects it. The analysis is conducted using the legal dogmatic method with EU interpretation, drawing on the V A T Directive, the V A T Implementing Regulation, the Court of Justice of the European Union (CJEU) case law and academic literature. To structure the analysis, three categories of platform-based services are examined: subscription-based access to digital content, platform- facilitated distribution of digital goods and services, and platform-mediated provisions of offline services.
The thesis concludes that the composite supply doctrine continues to apply to digital services, but that its role is shaped by the deemed supplier regimes. Where those regimes operate through Article 28 and 14a of the VAT Directive, they tend to consolidate supplier status at platform level, indirectly facilitating the composite supply assessment. Where they operate under Article 28a, the legislative fiction assigns the platform a fully taxable supply before any meaningful classification exercise takes place, potentially displacing the composite supply doctrine. More broadly, the thesis identifies a growing tension between the principle of economic reality underpinning the composite supply doctrine and the increasing legislative attribution of supplier status based on platform control. (Less)
Please use this url to cite or link to this publication:
https://lup.lub.lu.se/student-papers/record/9230479
- author
- Schneider, Anastasia LU
- supervisor
- organization
- course
- HARN60 20261
- year
- 2026
- type
- H1 - Master's Degree (One Year)
- subject
- keywords
- EU VAT, Composite Supplies, Deemed Supplier, Digital Services, Platform Economy, VAT Directive, ViDA, CJEU
- language
- English
- id
- 9230479
- date added to LUP
- 2026-06-04 10:29:50
- date last changed
- 2026-06-04 10:29:50
@misc{9230479,
abstract = {{The digitalisation of the economy has fundamentally challenged the application of the European Union’s (EU) value added taxation (VAT) law, regarding the classification of transactions involving multiple elements. Digital platforms frequently combine content delivery, payment processing, platform access and intermediation into integrated offerings, making it difficult to determine whether a transaction constitutes a single composite supply or multiple independent supplies. At the same time, the EU has specific deemed supplier regimes under which platforms may be treated as suppliers for VAT purposes, raising questions as to how these regimes interact with the traditional composite supply doctrine.
This thesis examines how the doctrine of composite supplies applies to digital services under EU VAT law, and to what extent the application of deemed supplier regimes affects it. The analysis is conducted using the legal dogmatic method with EU interpretation, drawing on the V A T Directive, the V A T Implementing Regulation, the Court of Justice of the European Union (CJEU) case law and academic literature. To structure the analysis, three categories of platform-based services are examined: subscription-based access to digital content, platform- facilitated distribution of digital goods and services, and platform-mediated provisions of offline services.
The thesis concludes that the composite supply doctrine continues to apply to digital services, but that its role is shaped by the deemed supplier regimes. Where those regimes operate through Article 28 and 14a of the VAT Directive, they tend to consolidate supplier status at platform level, indirectly facilitating the composite supply assessment. Where they operate under Article 28a, the legislative fiction assigns the platform a fully taxable supply before any meaningful classification exercise takes place, potentially displacing the composite supply doctrine. More broadly, the thesis identifies a growing tension between the principle of economic reality underpinning the composite supply doctrine and the increasing legislative attribution of supplier status based on platform control.}},
author = {{Schneider, Anastasia}},
language = {{eng}},
note = {{Student Paper}},
title = {{Bundled, Integrated and Deemed - The Classification of Composite Supplies in Digital Services under EU VAT}},
year = {{2026}},
}