ECJ C-231/19 Blackrock Investment Management (UK) – AG Opinion – VAT treatment of management services outside scope of the exemption

AG Opinion

Having regard to the foregoing considerations, I propose that the Court should reply to the question referred for a preliminary ruling by the Upper Tribunal (Tax and Chancery Chamber) (United Kingdom) as follows:

Article 135(1)(g) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax must be interpreted as meaning that a single supply of management services, such as that at issue in the main proceedings, which is provided by an IT platform belonging to a third-party provider to a fund management company and includes both special investment funds and other funds, does not fall within the scope of the exemption laid down in that provision.

Sources:

• Curia
• arendt.com
• KPMG
• meijburg.nl (Dutch)
• Deloitte (Dutch)
• Meijburg

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