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Comments on ECJ C-234/24: VAT Implications for Debt Collection and Invoice Factoring Services

  • VAT on Debt Collection Services: Services classified as ‘debt collection’ are subject to VAT, even if they fall under otherwise exempt payment services, while the granting of credits remains exempt without any such specific exclusion.
  • Advocate General Rantos’ Opinion: The recent opinion from Advocate General Rantos supports the German Tax Authorities’ position on “invoice factoring,” indicating that it aligns with existing VAT regulations.
  • UK VAT Considerations: In the UK, there are complexities regarding the application of debt collection VAT exemptions, as there is no specific carve-out in UK law, and interpretations may extend beyond current legal limits, potentially leading to VAT leakage in trade factoring scenarios when debtors default.

Source Fabian Barth

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