Recently, the CJEU has stated that shareholder contributions of a holding company to subsidiaries do not give rise to deduct input tax levied on the services that it obtains from third parties and supplies to the subsidiaries, for these input services have no direct and immediate links with the parent company’s own transactions but with the tax-exempt activities of the subsidiaries. Furthermore, costs of these obtained input services are neither included in the price of taxable transactions of the holding company in favor of the subsidiaries nor part of the general costs of the holding company’s own economic activity. However, a closer examination shows that VAT concerning services that are included in the price of the taxable transactions carried out by the subsidiary could be recharged to the subsidiary.
