Comments on ECJ case C-535/24: Self-Help Creditor Actions Not Taxable Supplies in Svilosa VAT Case

• The ECJ ruled that a company’s self-initiated efforts to recover its own funds do not constitute a taxable supply of services for VAT purposes.
• Svilosa, a Bulgarian holding company, hired lawyers to recover money lent to a foundation, but received no remuneration or request from the foundation.
• The Court clarified that a taxable supply requires a direct link between service and payment; Svilosa acted solely to protect its own interests.
• The Court rejected the idea that Svilosa’s actions were a “free supply” for non-business purposes, affirming they were linked to its economic activity.
• The case confirms that VAT applies only where there is reciprocity (service for payment), not for unilateral, business-motivated actions.

Source: ggi.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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