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AG opinion on Larentia + Minerva: VAT recovery for holding companies

Etienne Wong (Tax Chambers, 15 Old Square) looks at what the advocate general’s opinion in Larentia + Minerva means for holding companies seeking to recover VAT on share acquisitions. 

On 26 March 2015 the Advocate General delivered his opinion on the joined cases of Beteiligungsgesellschaft Larentia + Minerva mbH (C-108/14) (Larentia) and Marenave Schiffahrts AG (C-109/14) (Marenave) (reported in Tax Journal 10 April 2015)).
 
Larentia was a 98% limited partner in two limited partnerships that each operated a vessel. It provided each of these limited partnerships with administrative and business services for payment. Marenave was a holding company that acquired shares in four limited partnerships. It was also involved in the management of each of these for payment.
 
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