• Service: Tax, Tax & Legal Services, VAT
  • Type: Business and industry issue, KPMG information
  • Date: 13/03/2014

VAT treatment of pension scheme management services 

ATP case (C-464/12) - Background

VAT exemption applies to management services provided to certain types of special investment funds (known in Ireland as ‘qualifying’ funds). The ATP case concerned the VAT treatment of management services provided to a defined contribution occupational (“DC”) pension scheme.


ATP (the taxpayer) argued that DC pension schemes are the same as, or are sufficiently comparable to, funds which have previously been recognised by the CJEU as ‘qualifying’ funds and therefore management services supplied to DC pension schemes should be VAT exempt.


ATP also sought guidance on whether the particular services it provided constitute “management” of such a fund or if not may they fall under the VAT exemption for payments and transfers and/or operation, of bank accounts.


To read about the decision made on this case, download the PDF below.


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