Seller-scoped territories

Date: 2026-08-20 · Status: measured; deliberately no EuTerritories entry for either

Two territorial rates exist that this engine's territory map does not carry: the Greek Aegean islands' 30% reduction and the 19% standard rate in Austria's Jungholz and Mittelberg enclaves. Both were investigated for an entry, and for both the finding is the same: the rate follows the seller's establishment, not the destination — so for the cross-border supplies a territory lookup exists to price, the national rate is already the correct answer, and an entry would under-charge it.

The claim a territory entry makes

EuTerritories::for() answers from a destination — a country and a postcode. An own-rates entry therefore asserts: a supply landing here takes these rates, whoever the seller is. Madeira and the Azores satisfy that; these two regimes do not.

Austria — Jungholz and Mittelberg (19%)

§ 10 Abs. 4 UStG 1994 lowers the rate to 19% for supplies effected in the two enclaves by entrepreneurs with a residence, seat, habitual abode or establishment there — with carve-outs that send vehicle sales and supplies to mainland-Austrian establishments back to 20%. A seller in Vienna or Copenhagen charges 20% on a delivery into Jungholz. An entry keyed on the enclaves' postcodes would shave a point off every cross-border invoice, wrongly.

Greece — the Aegean islands (17 / 9 / 4)

From 2026-01-01 the regime is art. 26 of the Greek VAT Code (ν. 5144/2024, as amended by art. 11 of ν. 5246/2025): παρ. 4 keeps Lesvos, Kos, Samos and Chios conditioned on migrant-reception structures operating there; παρ. 4Α extends the 30% reduction to the islands of the North Aegean region, Samothrace and the Dodecanese with up to 20,000 inhabitants; παρ. 4Β excludes tobacco products and means of transport; παρ. 5 covers services. The reduction turns 24/13/6 into 17/9/4 (and the 4% level into 3%).

The conditions are the decisive part, spelled out in AADE circular Ε.2113/2025 (31.12.2025): for goods, the reduced rates require the goods to be on the islands and sold by a supplier established there, dispatched to a taxable person or non-taxable legal person established there, or imported by island residents. The circular's own Παράδειγμα 6 prices a mainland seller delivering an appliance to a private individual on Kalymnos at the normal rate. Services take the reduced rates only when the supplier is established on the islands and the service is materially executed there.

So the scenario a destination lookup answers — a seller somewhere else charging a consumer on the island — is exactly the scenario the regime excludes. The 2026 expansion of eligible islands changed nothing for this engine, because the scoping is what decides, and the scoping did not move.

What no-entry gets right, and what it cannot

• A cross-border or mainland seller invoicing a consumer on Chios or in Jungholz gets the national rate. Correct, per the regimes' own terms.
• A seller established on a qualifying island selling locally is entitled to 17/9/4, and this engine will price 24/13/6 — an over-charge, visible on the invoice, in the recoverable direction. Modelling it would need the seller's establishment as an input to territory resolution, not just the destination.

What would reopen this

1. Greece unconditions the rates — if a future amendment extends the reduction to consumer dispatches regardless of seller establishment, the islands become genuine destination territories and belong in the map.
2. Establishment-aware sellers — a consumer whose sellers are established on the islands (or in the enclaves) and who needs local pricing; the entry point would be seller establishment on TaxQuery, not a postal range.

Sources

• UStG 1994 § 10 Abs. 4 (RIS, Bundesrecht konsolidiert)
• Greek VAT Code ν. 5144/2024 art. 26, as amended by ν. 5246/2025 art. 11 (in force 2026-01-01); Α.1150/2021 (Β΄ 2828) remains in force for the four παρ. 4 islands
• AADE Ε.2113/2025 (31.12.2025, ΑΔΑ: ΨΨΑ046ΜΠ3Ζ-ΚΘΤ), esp. Παράδειγμα 6 and section III on services
• TEDB REGION heading, captured 2026-08-14: AT 19% "Jungholz, Mittelberg"; GR 17% "The Aegean Islands of Leros, Lesvos, Kos, Samos and Chios"