Advocate general Sharpston has given an opinion in the case PPG Holdings.

A taxable person who has established a pension fund as a separate entity for legal and fiscal purposes, in order to safeguard the pension rights of his employees and former employees, may not deduct the tax which he has paid on services supplied to that fund in connection with its management and operation. Such tax may be deducted only by the fund itself, from any tax which it is liable to pay on its own taxable transactions.

A-G CJ 18 April 2013, nr. C-26/12

 

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Rubriek: Europees belastingrecht, Omzetbelasting

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