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Circular No. 814 Clarifies VAT Treatment of Photovoltaic Installations

  • On 1 June 2026, Luxembourg’s AED issued Circular No. 814, confirming PV installations are immovable property and setting VAT treatment according to how the electricity is used — full sale to the grid, full self-consumption, or partial self-consumption with surplus sales. [marosavat.com], [bdo.lu]
  • Selling all output constitutes economic activity: the operator is a taxable person, sales attract the reduced rate, and input VAT on investment and maintenance is fully deductible; full private self-consumption falls outside VAT with no deduction. [marosavat.com], [regfollower.com]
  • The circular also details the €50,000 small-business franchise, electricity sharing, and adjustment obligations where an operator who deducted VAT later switches to full self-consumption within the 10-year adjustment period. [regfollower.com]

Article: Referencing CJEU case C-219/12 (Fuchs), the circular confirms that selling electricity for consideration on a continuing basis is economic activity even where output is below private consumption. Partial self-consumption keeps the operator taxable, allowing input VAT recovery but requiring the private-use share to be declared at market value. Sources: BDO, Marosa, official Circular PDF, Regfollower.



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