Home VAT grouping: review your group structure
VAT grouping: review your group structure
Several companies, shared activities and intercompany invoices. The facts within your group determine which VAT questions need attention.
Why are financial links in the news?
Sampension (T-268/25) concerns a 100% capital ownership requirement for certain VAT groups. The General Court held that such a requirement is not permitted unless necessary and appropriate to prevent abuse, fraud or avoidance. The judgment also states that Article 11 of the VAT Directive does not have direct effect.
What does this mean for your business?
The European case law is a reason to review existing assumptions carefully. It does not mean your companies automatically form a VAT group or can immediately change their invoicing.
An organisation chart alone is not enough for an assessment. Gather information about management, voting rights, activities and how the companies work together.
Prepare your group file
- The current structure, shareholdings and voting rights.
- Management arrangements and agreements within the group.
- A description of each company’s activities.
- Existing decisions, correspondence and examples of intercompany invoices.
Review the implications together
Valorem can help identify which aspects of your group structure require further examination. Include planned acquisitions, new activities and changes in control so the review reflects the business you intend to operate.
Would you like to discuss your VAT group structure?
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