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A temporary employment agency enquired whether subsidies received for carrying out labour intermediation activities should be included in the VAT taxable amount. The DGT ruled that, as there is a direct link between the payments received and the services provided, these amounts constitute consideration and are therefore subject to tax.
Question raised: Consideration of the subsidy as linked to the price.
Subsidies received for 'payment for actions' and 'payment for objectives' form part of the VAT taxable base due to the existence of a direct link between the provision of the mediation service and the amounts received. It is not necessary for the beneficiary of the subsidy to be the recipient of the service nor for the provision to be individualized. Accrual occurs when the services are provided, unless there are advance payments, in which case the tax accrues at the time of collection.
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