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A mixed holding company sought clarification on whether its participation in a cash-pooling system constituted an economic activity and whether the resulting financial returns should be included in its VAT deduction pro rata. The DGT ruled that the transfer of surplus funds is an economic activity subject to VAT; however, as the operation requires very limited resources, it is considered ancillary.
This ruling clarifies that cash-pooling activities, when performed with minimal resources, are treated as ancillary to the main business, potentially preventing them from affecting the VAT deduction pro rata calculation.
The tax team reviews your specific situation.
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