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VAT Application and Territoriality: Composite Offers and Fiscal Treatment Guidelines

This document, published on May 14, 2025, under legal identifier BOI-TVA-CHAMP-60-30 and available in PDF, discusses the VAT treatment of composite offers.

  • Principles of VAT Taxation: The common system of Value Added Tax (VAT) applies a tax proportional to the price of goods and services, treating each economic transaction independently. This means that taxable persons are taxed under uniform conditions for identical transactions, regardless of their overall economic performance or strategies.
  • Grouping Transactions: While each transaction is generally treated separately, a single tax regime may apply to complex transactions involving multiple elements (goods and services) that are closely linked. This ensures that transactions with a coherent economic purpose are not artificially divided for tax purposes, aligning with the VAT Directive.
  • Definitions and Legal Framework: The terminology used in VAT analysis, such as “transaction,” “element,” and “ancillary,” is crucial for determining how to classify and tax complex transactions. The legal framework allows for flexibility in applying tax rates, but it prohibits varying tax treatment based on the recipient’s use of the goods or services, ensuring consistency in VAT application.

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