Key legal question
Whether the sale of municipal waste-stamp labels was a direct representation exempt from VAT or indirect representation subject to VAT.
Extracted holding
The seller did not expressly act in the municipality's name and on its account, so the activity was indirect representation with two taxable transactions and the proceeds were subject to VAT.
Extracted reasoning
Direct representation under Art. 10 MWSTV requires express action in the name and on account of the represented person. The factual finding that this requirement was not met was binding, and nothing in the appeal called it into question.