VAT & Operations

VAT risks often arise in service relationships, holding and mixed structures.

VAT is not only a filing topic. In operating, holding and foundation-related structures, services, management fees, cost allocations, input VAT and mixed-use assets should be aligned before implementation.

Typical review topics

Organschaft

VAT group

Whether economic, financial and organisational integration creates or prevents VAT group effects.

Deduction

Input VAT

Input VAT depends on the actual use of services and assets, not only on invoices.

Allocation

Mixed supplies

Taxable, exempt and non-business activities require careful allocation and evidence.

Contracts

Intra-group services

Management, administration, IP, financing and shared services must be contractually and factually consistent.

Why this matters in structures

  • Holding and foundation structures may change service flows and cost allocation.
  • Incorrect VAT treatment can undermine pricing, accounting and tax documentation.
  • Cross-border services require review of place-of-supply rules and evidence.
  • The VAT story should match corporate tax, transfer pricing and banking documentation.

Outcome

  • Service relationship map and invoice logic.
  • Open VAT issues for local review.
  • Document list for contracts, invoices and allocation keys.
  • Implementation notes for accounting and ongoing compliance.
Review service flows