Comments on ECJ C-184/23: Internal services within VAT group not subject to VAT

The EU Court of Justice ruled that legally independent entities within a VAT group are not subject to VAT when providing services to each other for consideration, even if one entity performs exempt transactions. The CJEU also clarified that the recipient of the services not being able to fully deduct input VAT does not change this ruling.

Source Taxence

See also

• ECJ C-184/23 (Finanzamt T) – Judgment – Supplies within VAT group are outside scope of VAT even if input VAT is limited
• Roadtrip through ECJ Cases – Focus on ”VAT Grouping” (Art. 11)
• C-269/20 (Finanzamt T) – Judgment – Controlling company may be the only taxable person of a VAT group

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