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V2213-18 25 July 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · sociedad holding mixta

Mixed holding companies may deduct input VAT proportionally based on their operations

An entity operating car parks that manages its subsidiaries has enquired whether it can deduct VAT on its advisory and management services. The DGT has determined that, by providing management services, it acts as a mixed holding company and is entitled to proportional deduction.

The question raised

Deduction of Value Added Tax incurred on advisory services and the provision of management services to its subsidiaries.

The DGT's ruling

A holding company that provides management services to its subsidiaries has the status of an entrepreneur or professional (mixed holding). The VAT incurred on the acquisition of goods and services for its activity constitutes a general expense and is directly related to its economic activity. Therefore, it may deduct VAT proportionally to the amount of its transactions entitled to deduction.

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