Restructured pre-2008 tax credits not transferable to group VAT: Revenue Agency clarifies position

• Credits accrued by the parent company before 2008 cannot be transferred to the group
• A company joined the group VAT regime in 2005 and wrongly offset its own taxes with an IVA credit from 2004
• The company used a dispute resolution process in 2023 to fully pay the IVA and apply for recovery
• The question arose whether the credit should be transferred to the group, but it was clarified that it cannot be transferred
• The prohibition on transferring pre-2008 credits to the group has been in effect since 2008, regardless of when the credit was accrued

Source: eutekne.info

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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