The CJEU’s judgment makes clear that if factoring involves acquiring the management and collection of debts, there will very likely be a VAT-taxed service.
At first glance, the possible solutions, which have been developed together with the tax (legal) practice, seem to be a good approach to solve the bottlenecks.
It is intended to prevent investment funds qualifying as non-transparent (independently taxable) for a short period of time when the new rules take effect on January 1, 2025.
The Advocate General believes that Dutch pension funds are not sufficiently comparable to a UCITS for them to be regarded as a special investment fund.
