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VAT Exemption for Management of SIFs: First-tier Tribunal Decision in CCLA Case

  • First-tier Tribunal (FTT) considered VAT exemption for management of Special Investment Funds (SIFs)
  • Management of SIFs is VAT exempt under EU Principal VAT Directive (PVD)
  • Funds constituted as UCITS qualify as SIFs
  • Non-UCITS funds may benefit from SIF exemption if equivalent or comparable to UCITS
  • State supervision must be financial in nature, indirect supervision via fund manager is sufficient
  • FTT considered each fund case-by-case, some met requirements for VAT exemption
  • VAT exemption applies to some management services under consideration

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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