Etienne Wong (Old Square Tax Chambers) and Alex Tostevin (Dentons) compare the VAT treatment of direct investment and investment through a fund in the light of recent EU cases.
Article 135(1)(g) of the Principal VAT Directive (the Directive) exempts the ‘management of special investment funds as defined by member states’. ‘Special investment funds’ (SIFs) is clearly a term of art and because of that it is perhaps not surprising there has been so much confusion and controversy over its meaning (see our article ‘VAT and the evolution of the special investment fund’ in Tax Journal 16 November 2018).
In this article we turn to the other limb of the exemption: ‘management’. This is a term with an ordinary everyday meaning; but in a tax context – a VAT context especially – it is as much a term of art as ‘special investment funds’.
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Etienne Wong (Old Square Tax Chambers) and Alex Tostevin (Dentons) compare the VAT treatment of direct investment and investment through a fund in the light of recent EU cases.
Article 135(1)(g) of the Principal VAT Directive (the Directive) exempts the ‘management of special investment funds as defined by member states’. ‘Special investment funds’ (SIFs) is clearly a term of art and because of that it is perhaps not surprising there has been so much confusion and controversy over its meaning (see our article ‘VAT and the evolution of the special investment fund’ in Tax Journal 16 November 2018).
In this article we turn to the other limb of the exemption: ‘management’. This is a term with an ordinary everyday meaning; but in a tax context – a VAT context especially – it is as much a term of art as ‘special investment funds’.
...
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