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Larenta & Minerva – CJEU Judgment (Holding Companies & VAT Groups)


The CJEU has backed the Advocate General’s earlier opinion that VAT incurred on the acquisition of subsidaries can be reclaimed in full providing the holding company is engaged  in wholly taxable economic activities and that the costs incurred for a component of that activity. If the holding company also controls subsidiaries to which no services are applied then apportionment may be required.