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Advance Tax Ruling: Voluntary VAT Registration for Leasing Care Homes to Municipality for Elderly Care

  • The case concerns whether a company can obtain voluntary VAT registration and deduction rights for renting out care homes to a municipality, which will sublet them to elderly people with 24-hour care decisions.
  • The company seeks confirmation that entering a lease agreement with the municipality is sufficient for voluntary registration and VAT deduction, without needing sublease agreements with individual residents.
  • The lease agreement with the municipality is planned for at least 30 years, with the municipality using the premises as care homes and common areas for elderly residents.
  • The request for a binding advance ruling is made on behalf of a future wholly owned subsidiary, with plans to sell 50% of its shares to an external company, which should not affect the assessment.
  • All formal requirements for the advance ruling are met, and the necessary fee has been paid.

Source: skatteetaten.no

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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