Opinion Statements

CFE Opinion Statement FC 05/2017 regarding the VAT exemption of services provided by an independent group of persons (Article 132 (1) (f) of Directive 2006/112/EC)

On 1 March 2017 Advocate General Juliane Kokott delivered her Opinion in Case C‑605/15 Minister Finansów  v. Aviva Towarzystwo Ubezpieczeń na Życie S.A. w Warszawie.

The case concerned the scope of the VAT exemption commonly referred to as the "cost sharing associations exemption" in Article 132 (1) (f) of Directive 2006/112/EC. 

Due to the significance of this VAT exemption for many economic operators, the CFE considers that it is important to make a few technical comments on the position adopted by Advocate General Juliane Kokott.

We invite you to read our comments presented in the document below.  


CFE Opinion Statement : Response to Consultation on the OECD BEPS Action 6 Public Discussion Draft on non-CIV examples

On 2 February 2017 the CFE Fiscal Committee submitted the folowing Opinion Statement in response to an OECD Public Consultation entitled: 

'Interaction between the tax treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds'

The Discussion Draft includes three draft examples with regard to the treaty entitlement of non-CIV Funds when applying the principle purpose test (hereinafter “PPT”) as described in the BEPS Action 6 final report. The CFE response provides comments on these three draft examples.

The CFE Response is available here.