Keywords
Summary

Keywords

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Tax provisions - Harmonization of legislation - Turnover taxes - Common system of value-added tax - Exemptions provided for by the Sixth Directive - Strict interpretation - Exemption of services supplied by independent groups of persons exercising an activity which is exempt or for which they are not taxable, for the purpose of rendering services to their members - Organization and performance by a foundation of services which are related to the activities of another foundation which qualifies for the exemption - Not permissible

( Sixth Council Directive ( 77/388/EEC ), Art . 13(A)(1)(f ) )

Summary

The exemptions provided for in Article 13 of the Sixth Directive ( 77/388/EEC ) on the harmonization of the laws of the Member States relating to turnover taxes constitute exceptions to the general principle that turnover tax is levied on all services supplied for consideration by a taxable person . Therefore, the terms used to specify the exemptions are to be interpreted strictly . Consequently, and having regard to the precise formulation of the conditions for exemption laid down in Article 13(A)(1)(f ) relating to services supplied by independent groups of persons exercising an activity which is exempt or for which they are not taxable, for the purpose of rendering services to their members, the transactions which are exempted pursuant to the aforesaid provision do not cover the activities of a foundation which consist exclusively in the organization and performance of services which are related to the activities of another foundation, against reimbursement of expenses actually incurred, where the other foundation acts as an umbrella organization for a number of bodies exercising an activity which is exempt or for which they are not taxable and, solely for those bodies, performs services as described in the aforesaid provision of the Sixth Directive .