- The Italian Revenue Agency clarified that special purpose vehicles (SPVs) in MLBO operations qualify as VAT taxable persons.
- SPVs have the right to deduct VAT on transaction costs incurred for the acquisition, as these costs are directly linked to the future economic activity of the merged entity.
- The clarification aligns with both EU and Italian case law, recognizing the preparatory role of SPVs in economic activities post-acquisition.
- SPVs are not considered entities created solely for holding shares; their transaction costs are deemed preparatory expenses for the target company’s economic activity, justifying VAT deduction.
Source: eutekne.info
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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