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No VAT Exemption for Pension Fund Management Services Covering Both Accumulation and Payout Phases

  • X provided management services to a pension fund and charged a single fee for both the accumulation and payout phases.
  • The dispute concerns whether these services are exempt from VAT as management of a collective investment fund.
  • The court ruled that only the accumulation phase involves investment risk for participants, which could qualify for exemption.
  • The service is considered a single, indivisible performance covering both phases, so the fee cannot be split.
  • Since part of the service does not qualify for exemption, the entire service is not exempt from VAT; X’s appeal is dismissed.

Source: nlfiscaal.nl

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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