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Date of publication
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27 Oct 2022 10:42 |
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Date of delivered judgment/
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27 Sep 2022 09:59 |
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SKM number
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SKM2022.516.SR |
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Authority
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The Tax Council |
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Responsible board
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The Danish Tax Agency |
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Case number
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22-0048796 |
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Document type
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Binding answer |
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Parent topics
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VAT and payroll tax |
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Parent topics
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VAT exemption and reimbursement |
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Subject word
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VAT exemption – mediation – securities |
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Summary
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The questioner and X have entered into an Investment Advisory Agreement regarding five funds that X manages. Pursuant to the agreement, the inquirer must provide non-discretionary investment advice and related services.
Based on the presented agreement, it is the Tax Council’s assessment that the main service in the agreement must be considered a VAT-exempt transfer, cf. VAT Act section 13, subsection 1, no. 11, letter e). As far as the related services covered by the agreement are concerned, the Tax Council is of the opinion that these must also be considered VAT-exempt, apart from the services in the form of assessing the performance of other portfolio managers on behalf of the management company and providing currency transactions etc. |
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Authorization
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Tax Administration Act § 21, subsection 4, No. 1 |
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Reference(s)
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Section 13 of the VAT Act, subsection 1, no. 11, letter e) |
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Reference
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Legal guidance 2022-2, section DA5.11.8.1 |
Source: skat.dk
