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A financial professional enquired whether the management of accounts held for private clients in the EU or Switzerland was subject to VAT and how to calculate the taxable base. The DGT ruled that liability depends on the client's location and that the taxable base for pro-rata calculations is based on the positive consideration from foreign exchange transactions.
Question raised: Liability for Value Added Tax on said services, as well as the taxable base of the services provided.
Management services provided to clients who are not entrepreneurs or professionals are subject to VAT if their habitual domicile or residence is in a European Union Member State. They shall not be subject to VAT if the recipient is not an entrepreneur and resides outside the European Union. For the calculation of the pro rata, the taxable base shall be the positive consideration obtained in foreign exchange transactions that generate payable consideration upon the cancellation of positions.
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