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A variable capital investment society (SICAV) harmonised with exempt VAT activity asks whether it must submit the annual declaration of operations with third parties (Model 347). The DGT considers that, as a joint stock company, the SICAV qualifies as a trader or professional, and its management services are subject to and exempt from VAT under Article 20.18.n of the VAT Law. The obligation to file Model 347 depends on whether there is an obligation to issue invoices for these exempt operations, according to the invoicing rules.
Question posed: Whether a harmonized open-ended investment company with VAT-exempt activity has the obligation to submit the annual declaration of transactions with third parties.
The SICAV, as a public limited company, is presumed to have the status of entrepreneur or professional (Art. 5.One.b LIVA). Its management services are subject to and exempt in accordance with Art. 20.One.18.n LIVA. Art. 3.2 of the Invoicing Regulations establishes an exception to the obligation to issue an invoice for the services referred to in Art. 20.One.18 LIVA, with certain nuances for entities such as collective investment scheme managers. The obligation to submit Form 347 (Art. 31 RGAT) applies only when business or professional activities are carried out that generate a declaration obligation.
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