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V2273-25 ·25 November 2025 ·consulta-vinculante Medium impact
Tax

Requirements for VAT exemption on management services provided to a securitisation fund

An entity asks whether administration and credit rights management services provided to a securitisation fund are exempt from VAT. The DGT states that, according to TJUE case law, for externalisation to be exempt, it must constitute a distinct package and be specific and essential to the fund's management.

In 6 key points

How it affects those involved

Service providers must ensure that externalised management activities are distinct and specifically essential to the fund's operations to qualify for VAT exemption.

Lifecycle

2025-11-25PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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