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Comments on ECJ C-184/23: AG Opinion on Intra-VAT Group Services

  • CJEU considered the status of controlling members of German VAT groups in two judgments in 2022
  • U-GmbH provided cleaning services to its parent foundation S, which ran a university teaching hospital
  • AG Rantos believed that the cleaning services should not be treated as supplies of services as they occurred between two members of a VAT group
  • Intra-VAT group supplies should be regarded as a flow of funds, not taxable supplies
  • VAT groups exist to simplify administration and prevent abuse, as well as support organizational fiscal neutrality
  • German tax authorities’ concerns about tax loss were considered misplaced by AG Rantos
  • U’s services to S were not within the scope of VAT according to AG Rantos.

Source: taxscape.deloitte.com



 

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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