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VAT-exempt transfer of securities

Date of publication
27 Oct 2022 10:42
Date of delivered judgment/ order/ decision/ control signal
27 Sep 2022 09:59
SKM number
SKM2022.516.SR
Authority
The Tax Council
Responsible board
The Danish Tax Agency
Case number
22-0048796
Document type
Binding answer
Parent topics
VAT and payroll tax
Parent topics
VAT exemption and reimbursement
Subject word
VAT exemption – mediation – securities
Summary
The questioner and X have entered into an Investment Advisory Agreement regarding five funds that X manages. Pursuant to the agreement, the inquirer must provide non-discretionary investment advice and related services. 

Based on the presented agreement, it is the Tax Council’s assessment that the main service in the agreement must be considered a VAT-exempt transfer, cf. VAT Act section 13, subsection 1, no. 11, letter e).

As far as the related services covered by the agreement are concerned, the Tax Council is of the opinion that these must also be considered VAT-exempt, apart from the services in the form of assessing the performance of other portfolio managers on behalf of the management company and providing currency transactions etc.

Authorization
Tax Administration Act § 21, subsection 4, No. 1
Reference(s)
Section 13 of the VAT Act, subsection 1, no. 11, letter e)
Reference
Legal guidance 2022-2, section DA5.11.8.1

Source: skat.dk

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