The services provided by X are indeed indispensable in view of the software design for the realization of transfers, but these services do not change either the legal or the financial relationships. With what the interested party has put forward, the court is therefore of the opinion that the interested party has not made it plausible that X’s services, viewed individually and together, fulfill the characteristic and essential functions of transfers and/or ‘current account transactions’ within the meaning of the exemption. In the opinion of the court, the principle of fiscal neutrality does not stand in the way of the conclusion that the activities that X performs for the interested party do not meet the conditions for applying the exemption.
Source: rechtspraak.nl
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