The Revenue Agency expressed its opinion on the services attributable to the “management of mutual investment funds’, for the purposes of the VAT exemption pursuant to art. 10 paragraph 1 nos. 1), 4) and 9) of Presidential Decree 633/72 In the present case, the applicant company is an asset management company that has set up a closed-end alternative investment fund; it intends to make use of the services rendered by an advisor for the marketing of the units of this fund (so -ealled fundraising services ). For the purposes of the VAT exemption, for the comparability of a mutual fund to a UCITS, it is necessary that the same – in addition to being subject to “specific state supervision” is participated by several investors who are entitled to the benefits or bear the associated risk to its management. Furthermore, the return on the investment made must depend exclusively on the results of the management of the fund itself.
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