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Fund Management: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Refined position High confidence 13 rulings · 2015–2025

Current position

Advisory services for the purchase and sale of assets and investment recommendations are exempt from IVA (Value Added Tax) if they have an intrinsic link to the management company's activity. This exemption applies to services delegated to third parties as long as the delegation does not turn the management entity into an instrumental or empty entity. Furthermore, the criteria of the GfBk ruling regarding essential services must be met.

The DGT's position remains stable regarding the exemption of advisory and management services for IIC (Collective Investment Schemes). The evolution shows an integration of case law, specifically the incorporation of the criteria from the GfBk ruling to validate the delegation of functions to third parties without losing the exemption.

Turning points

  1. V1151-21

    Introduces the need to comply with the criteria of the GfBk ruling so that the delegation of services to third parties maintains the IVA exemption.

Analysis based on 11 of 13 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

13

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