Since the amendment of the Sixth Directive in the context of the abolition of internal frontiers, there has been a debate on the relationship between the "Transitional arrangements for the taxation of trade between Member States", inserted in the new Title XVIa of the Sixth Directive, and the rules contained in the original titles of the Directive, in particular, as regards the place-of-supply rules applicable to intermediary services. In this judgment of 27 May 2004 in the Lipjes case, the ECJ more or less resolved the issue. This article examines the legal issue and the ECJ judgment, and discusses alternative solutions.