Comments on ECJ C-250/21: VAT exemption for sub-participation

A number of Polish banks securitised loans with O. Fundusz, which advanced them a ‘financial contribution’ in return for undertaking under a sub-participation agreement to pass any loan repayments to the fund. The banks were clearly making VAT-exempt supplies of credit to their customers. Was O. Fundusz making an exempt supply of credit to the banks?

Source Deloitte

See also ECJ C-250/21 (O. Fundusz lnwestycyjny zamknięty reprezentowany przez O) – Judgment – Exemption for the granting of credits apply applies to sub-participation agreements

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