Article 135(1)(g) of the Principal VAT Directive (PVD) exempts the ‘management of special investment funds as defined by member states’. Tax authorities and taxpayers have clashed repeatedly over the exemption – specifically over what amounts to ‘management’ and what precisely ‘special investment funds as defined by member states’ means – and litigation continues. There is no better illustration of the confusion that pervades than the UK legislation taking over 500 words to implement a ten word exemption. This reflects the ‘band-aid’ style approach the UK has been taking reacting to each judicial decision as it comes rather than coming to grips with the underlying concepts. To be fair...
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Article 135(1)(g) of the Principal VAT Directive (PVD) exempts the ‘management of special investment funds as defined by member states’. Tax authorities and taxpayers have clashed repeatedly over the exemption – specifically over what amounts to ‘management’ and what precisely ‘special investment funds as defined by member states’ means – and litigation continues. There is no better illustration of the confusion that pervades than the UK legislation taking over 500 words to implement a ten word exemption. This reflects the ‘band-aid’ style approach the UK has been taking reacting to each judicial decision as it comes rather than coming to grips with the underlying concepts. To be fair...
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