Etienne Wong (Old Square Tax Chambers) looks at the recent CJEU ruling in Ryanair on holding companies recovering VAT on abortive takeover bids.
Holding companies are the Bermuda Triangle of the VAT world. They attract more than their fair share of disputes and in the same way that compasses on planes sometimes lose north when they enter the Triangle with holding companies a form of analytical vertigo sometimes takes over to obscure ordinarily simple principles.
Ryanair (Case C-249/17) is a case in point.
Background
In 2006 Ryanair (the airline) made a formal bid to take over Aer Lingus (another airline and thus a competitor). For competition law reasons Ryanair was barred from acquiring the whole of the share capital (although it was still able to acquire roughly 29% of the shares).
The issue was whether Ryanair was entitled to deduct the VAT it...
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Etienne Wong (Old Square Tax Chambers) looks at the recent CJEU ruling in Ryanair on holding companies recovering VAT on abortive takeover bids.
Holding companies are the Bermuda Triangle of the VAT world. They attract more than their fair share of disputes and in the same way that compasses on planes sometimes lose north when they enter the Triangle with holding companies a form of analytical vertigo sometimes takes over to obscure ordinarily simple principles.
Ryanair (Case C-249/17) is a case in point.
Background
In 2006 Ryanair (the airline) made a formal bid to take over Aer Lingus (another airline and thus a competitor). For competition law reasons Ryanair was barred from acquiring the whole of the share capital (although it was still able to acquire roughly 29% of the shares).
The issue was whether Ryanair was entitled to deduct the VAT it...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
