Comments on ECJ C-232/24: AG Opinion on VAT for Factoring and Arrangement Fees

• Advocate General delivered opinion on April 3, 2025, in case C232/24 Kosmiro
• Case concerns VAT treatment of factoring commissions and arrangement fees
• AG concluded these fees are subject to VAT as they are remuneration for services
• Factoring activities involve debt collection, excluded from VAT exemption
• Opinion could affect VAT treatment of structured finance services in the EU
• Review current finance arrangements and VAT treatment in light of this opinion
• Consider implications of pending A Oy case on VAT treatment of loan servicing

Source: alvarezandmarsal.com

See also

• C-232/24 (Kosmiro) – AG Opinion – Factoring fees subject to VAT; direct effect of EU provisions

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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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