Persistent failure to comply with tax obligations – Removal of the taxable person from the value added tax (VAT) identification register – Principle of proportionality
Concepts of ‘taxable person’ and ‘economic activity’ – Sale of agricultural land for residential development – Preparation for sale by an agent acting as a professional trader – Statutory joint ownership of assets between co-owning spouses
AG opinion concerning VAT implications of transfer pricing adjustment
Sales transaction reclassified by the tax authorities as a transfer of an undertaking falling outside the scope of VAT – Failure to correct the invoice within the limitation period – Impossibility of recovering the VAT paid in respect of that transaction – Principles of effectiveness and fiscal neutrality – Reimbursement of the tax
Directive 2006/112/EC – Article 205 – Joint and several liability for tax debts owed by a third party – Conditions and scope of liability – Fight against VAT fraud – Joint and several liability for the payment of VAT which does not allow an assessment to be made on the basis of the contribution of each taxable person in the tax evasion – Principle of proportionality – Article 50 of the Charter of Fundamental Rights of the European Union – Principle non bis in idem – Criteria for application – Facts relating to different tax years against which administrative or criminal proceedings are brought – Continuing offence with unity of purpose – Facts not identical
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Directive 2006/112/EC – Article 168 – Right to deduct VAT – Purchase of administrative services provided within the same group of companies – Refusal of the right of deduction
Directive 2006/112/EC – First paragraph of Article 183 – Rules governing the exercise of the right of deduction – Carrying forward excess VAT – Concept of ‘following period’ – Refund of excess VAT – Cessation of economic activity
Directive 2006/112/EC – Article 2(1)(c) – Scope – Taxable transactions – Contract for services for the carrying out of a building project – Termination of the contract by the customer – Concept of ‘remuneration’ – Characterisation – Obligation to pay the total amount agreed after deduction of the costs saved by the supplier – Article 73 – Taxable amount
Reference for a preliminary ruling – Environment – Regulation (EU) No 995/2010 – Obligations of operators who place timber and timber products on the market – Article 2(a) to (c) – Concepts of ‘timber and timber products’, ‘placing on the market’ and ‘operator’
SEM Remont’ EOOD v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna prakti-ka’ Varna pri Tsentralno upravlenie na Natsion-alnata agentsia za prihodite C624/23 (SEM Remont’ EOOD v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna prakti-ka’ Varna pri Tsentralno upravlenie na Natsion-alnata agentsia za prihodite C624/23)
Directive 2006/112/EC – Deduction of VAT – Principle of neutrality of VAT – Late submission of an application for registration – Issuing and content of invoices – Invoice which does not state input VAT – Tax calculated on the basis of a report – Absence of a correcting invoice – Right of deduction – Precluded