The ECI held (see C-868/19 Finanzamt für Körperschaften Berlin) that it is from the outset not compatible with EU-Law if the possibility for a partnership to form a VAT group – in addition to the controlling company – is limited to those partners in the partnership whose business is financially integrated into that of the parent. Such a restriction can only be justified by a specific need to prevent abuse.
Source: PwC DE
