The pension fund doesn’t qualify for the VAT exemption on the management of collectively invested assets because participants don’t bear the investment risk as required for the exemption; instead, pension benefits are primarily based on pensionable income and years of service. The court rejected the appeal to fiscal neutrality, noting that investment results only affect indexation and reductions, not the basic entitlements, and participants have guaranteed claims without individual investment choices, unlike Defined Contribution funds.
Source: btwjurisprudentie.nl
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