Thesis: Composite Supplies in the Common System of VAT

Source Giacomo Lindgren Zucchini

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Thesis

Abstract

This thesis is about the tax treatment of composite supplies in the common system of value added tax (VAT) of the European Union. A composite supply is a single supply that consists of various distinguishable parts that are combined to form a cohesive unit assessed as such for VAT purposes, even though at least some of those parts might constitute their own single supplies in other circumstances.

Many issues need to be resolved as regards composite supplies. In particular, it is vital to determine the identity of single supplies, that is to say, whether a transaction comprising various parts constitutes one or more single supplies. This may result in certain single supplies having a particular composition of parts and that therefore constitute composite supplies. In turn, the specifics concerning the identity and composition of single supplies have numerous implications for how their ultimate tax treatment with regard to taxation or exemption is decided.

The thesis studies how to determine what constitutes a single supply; in particular with respect to those that are composite supplies. Furthermore, it also studies how the various aspects of the tax treatment with regard to taxation or exemption are decided for different kinds of composite supplies. This includes how the place of supply of such composite supplies is determined, how it is decided whether they are subject to exemptions, and how it is assessed whether a particular rate of tax applies.

ECJ Cases

• C-224/11 – BGŻ Leasing sp. z o.o – Leasing services supplied together with insurance for the leased item
• Composite Supplies under EU VAT: Closer Encounters of the Third Kind?

 

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